EACB answer to the ECB consultation on Guide on the the supervisory approach to consolidation in the banking sector

The European Association of Co-operative Banks (EACB) appreciates that the Guide does not set regulatory requirements and we appreciate that the ECB sees that mergers and takeovers are the result of market forces and shareholders decisions. We would recommend, however, a number a clarifications particularly with regard to the scope of application of the Guide and the calculation of the Pillar 2 requirements after a consolidation operation.