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EACB - European Association of Co-operative Banks

Question 1: Is the scope of application of the guidelines appropriate and sufficiently clear?
Please see attached document.
Question 2: Is the date of application of the guidelines of 1 January 2018 appropriate?
Please see attached document.
Question 3: Please provide any comments you may have on the appropriateness of the proposed proportionality approach.
Please see attached document.
Question 4: Do you agree with the draft guidelines which introduce the relevant BCBS Guidance in the EU regulatory framework? Are there additional issues for which the EBA Guidelines should be amended in the context of finalising the guidelines?
Please see attached document.
Question 5: Do you agree with the impact assessment and its conclusions, having regard to the baseline scenario used for this impact assessment? Please provide any additional information regarding the costs and benefits from the application of these guidelines.
Please see attached document.
Question 6: Please provide any additional comments on the draft guidelines.
Please see attached document.
Contact name
Marco Mancino