Response to consultation on Guidelines on ICAAP and ILAAP information

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1) 1. What are your views on the scope and specification of information to be collected for the purposes of the assessment of ICAAP and ILAAP under SREP specified in the draft Guidelines?

In general, we agree with the scope and specification of information to be collected. Nevertheless, we note that the current information specification seems to be aiming towards a standardised information provision, which is against the EBA's intention of not specifically addressing how ICAAP/ILAAP should look like.

2) 2. What are your views on the general criteria for the organisation of the collection of ICAAP and ILAAP information as specified in Section 4 of the draft Guidelines?

We agree with the general criteria for the organisation of the collection of ICAAP and ILAAP information, although we feel that in certain cases, more clarity is required on the information to be provided.

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Name of organisation

British Bankers' Association