Submission #16

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EACB - European Association of Co-operative Banks

Question 1: Are the Subject matter, scope and level of application within Article 1 appropriate and sufficiently clear? Please refer to attached document.

Question 2: Are the definitions within Article 2, 3 and 4 appropriate and sufficiently clear? Please refer to attached document.

Question 3: Are the qualitative criteria within Article 6 appropriate and sufficiently clear? Having in mind that the qualitative criteria are comparable to the ones included in the RTS currently in force, respondents are asked to focus on the amended criteria within points 1 and 6. Please refer to attached document.

Question 5: Are the provisions within Article7 appropriate and sufficiently clear? Please refer to attached document.

Question 6: Are the provisions within Article 8 appropriate and sufficiently clear? Please refer to attached document.

Question 7: Considering that the RTS will apply to all credit institutions, are there specific provisions within the RTS that would not be appropriate to be applied to small and noncomplex institutions and should be replaced by different provisions? Where this is the case, respondents are provided to make concrete examples of issues created and alternative approaches that would ensure that all staff whose professional activities have a material impact on the risk profile of the institution are identified. Please refer to attached document.

Question 8: Do respondents with the findings of the impact assessments? Where respondents have comments on the additional cost and benefits created by the consulted RTS, comments are most helpful if they detail the costs and the responsible drivers as well as the challenges when applying the criteria set out within the RTS. Where respondents find that the criteria lead to an identification of staff that does not have a material impact on the institutions risk profile, comments are most helpful if they detail the numbers of staff identified under the criteria and the main reasons why those staff members would systematically not have a material impact on the institutions risk profile. Please refer to attached document.

Upload files EACB comments on amendments to RTS on MRTs.pdf

Name of the organization EACB - European Association of Co-operative Banks