The EBF has commented on various parts of the consultation paper, which are further elaborated in the response.
he European Banking Federation has responded to the consultation of the European Banking Authority
regarding its review of the Guidelines on common procedures and
methodologies for the supervisory review and evaluation process.
The EBF has commented on various parts of the consultation paper,
which are further elaborated in the response. The response of the EBF in
particular (among other topics) comments on the:
- Inclusion of ML/TF risks in the SREP Guidelines,
- The recognition of Single Point of Entry (SPE) and Multiple Point of Entry (MPE) structures,
- The inclusion of climate risk in P2G,
- Diversification between risks and geographies,
- The setting of Pillar 2 Guidance,
- Pillar 2 Requirement and Pillar 2 Guidance for excessive leverage,
- The principle of proportionality,
- Temporary capital add-ons, and
- Transparency with regard to decisions made in the context of Pillar 2
Full response
EBF
© EBF
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