The EBA indicates in the executive summary that the final GL are planned to be applicable from 30/06/2016. The consultation period closes on 11/03/2016. Depending on the development of the work stream it may happen that the publication of the final GL occurs almost at the same time of their initial applicability. In light of this, institutions will not be provided with the necessary implementation period. In addition it is also indicated that Competent Authorities may require their ICAAP/ILAAP information for the 2016 SREP based on the draft GL. These could however be subject to change, and create misunderstandings and undue implementation costs. Such consequences should be avoided especially in light of regulators’ effort for a simpler and better regulation.
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