The EACB welcomes the opportunity to comment on the draft EBA GL on the criteria to assess the exceptional cases when institutions exceed the large exposure limits of Article 395(1) CRR and the time and measures to return to compliance pursuant to Article 396(3) CRR.
At a general level, we appreciate the fact that EBA’s approach very much built on existing supervisory practices that are known and clear to institutions.
We nevertheless have some recommendations with regards to the presentation of streamlined compliance plans and for return to compliance on periods longer than one year.