The members of the European Association of Co-operative Banks (EACB) welcome the opportunity to comment on the consultation on recognition of IPS for prudential purposes.
While we appreciate the intention of the Draft Guide to maintain as much flexibility as possible, we nevertheless believe that the consultation document is too general and vague in many places; this makes it difficult in many instances to understand the core of the ECB's approach and how the SSM will apply many of the elements included.
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