The Members of EACB welcome the opportunity to comment on the SSM draft Guideline and draft Recommendation on the exercise of options and discretions available in Union law for less significant institutions (LSIs). We appreciate that the proposal was inspired by the proportionality principle, this is essential to ensure that the application of the O&D policies does not lead to an undue burden for LSIs. However, we highlight some areas where adjustments are still needed and flexibility for the NCAs is necessary to attain a level playing field.
