Response to consultation on guidelines on criteria to to assess other systemically important institutions (O-SIIs)

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Question 2: Do you agree that there may be Member States where small institutions are unlikely to pose systemic threats to the domestic economy? Do you think the option to exclude these institutions could reduce the administrative burden for institutions, or do you think there is a risk that the results of the analysis could be distorted by excluding them?

In our point of view, the answer depends on concentration in Member States.If concentration in Member States is low, small institutions matter; otherwise – not.

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Name of organisation

Association of Russian Banks