Response to consultation on Guidelines for common procedures and methodologies for SREP

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Question 1: What are the respondents’ views on the overall amendments and clarifications added to the revised guidelines?

Please see attached document.

Question 2: What are the respondents’ views regarding ‘the interaction between SREP and other supervisory processes, in particular assessment of recovery plans’ provided in the ‘Background and rationale’ section?

Please see attached document.

Question 3: What are the respondents’ views on how the assessment of internal governance and institution-wide controls has been aligned with the revised EBA Guidelines on internal governance (Section 5)?

Please see attached document.

Question 4: What are the respondents’ views on the provisions of the newly introduced Pillar 2 Capital Guidance?

Please see attached document.

Question 5: What are the respondents’ views regarding disclosure of P2G (paragraph 403), having in mind the criteria for insider information?

Please see attached document.

Question 6: What are the respondents’ views on the introduction of supervisory stress testing in the revised guidelines (Section 12)?

Please see attached document.

Name of organisation

EACB - European Association of Co-operative Banks