Response to consultation on Guidelines on Connected Clients

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Question 8: Are the situations described in the list in paragraph 23 as constituting economic dependency clear? If not, provide concrete suggestions. In particular, do you have any comments regarding the introduction of the threshold of ‘at least 50%’ in points c), d), f) and g)?

There might be a source of missunderstandings in paragraph 23 point e) regarding the following case:
If two or more natural persons are working for the same employer, does this connection qualify as the expected source of repayment" for their individual loans (not talking about co-borrowers here) being the same (as they get their salary from the same legal person)?
Please clarify this constellation in the final guideline."

Name of organisation

Vorarlberger Landes- und Hypothekenbank Aktiengesellschaft