The European Association of Co-operative Banks (EACB) would like to thank the European Banking Authority (EBA) for the possibility to comment on the proposed guidelines. It has carefully reviewed the consultation document with its members and would like to formulate a number of observations. Some of these are relating to the set of proposed guidelines as a whole ("general comments") and some are answers to the specific questions raised. As the answer form on the website does not allow for general comments, they have been formulated in this document.
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