(a) The Draft recommendation outlines the list of topics to be adequately covered for the “group relevant” entities within the Group Recovery Plan, including the governance, indicators, options and scenarios. We would recommend providing a guidance also on the interconnections analysis and communication strategy arrangements on the local level for such entities, if they should be included in the Group Plan or not, given the direct link of these two topics with options & scenarios.
(b) The BRRD stresses the importance of having intra-group financial support arrangements among recovery options¹. Should be there any link and/or dependency between intra-group support recovery options and entity classification? In other words, should the Group Recovery Plan have intra-group support as a recovery option for all entities considered group relevant?
(a) We would welcome further clarification and development on what is precisely meant for “confirmation” (35). Are there Local approval, Non-binding opinion, Independent legal opinion envisaged? Should these “confirmation” evidences be attached to the Group Recovery Plan?
(b) For large banking organizations the possibility of having a lot of local relevant entities is not nil and could lead to increase of the volume of information to be included in the Group Recovery Plan, and add more complexity in reading and understanding the Plan. We would recommend to provide the possibility to disclose this information in an Appendix to the Group Plan instead of having it in the main text of the Plan.