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European Banking Federation

No comment.

See general comments in attached document.
See general comments in attached document.

• Past performance of receiving entity can be used for assessment.
• Reputational impact of allowing a subsidiary to fail should be considered.
See general comments in attached document.

• Maintaining BAU capital limits e.g. large exposures will limit the amount of group support that can be provided.
See generalcomments in attached document.

• As above, authorities should consider allowing temporary breaches of ratios to enable provision of group support to the extent required by receiving entity.
See generalcomments in attached document.

• See comments for questions 3 and 4
See generalc omments in attached document.

• The rules may encourage regional funding models vs. centralised funding models. This needs to be considered in context of appropriate resolution strategy (ie SPE or MPE)
See general comments in attached document.

No comment.
Timothy Buenker
E