The members of the EACB welcome the opportunity to comment on the EBA draft GL on payment commitments under DGSD.
“We believe that these guidelines should not aim to further restrict the national implementation of the DGSD, but instead use a “substance over form” – approach: as long as the goals and provisions of the DGSD are met by the DGS in the different Member States (in particular by ensuring security and rapid availability of payment commitments), it should be possible to take into account specific national features in the course of implementation”.
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