The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the amendments to the RTS on material risk takers, which takes into account the updates brought about by the CRD V finalised in 2019.
We appreciate that the EBA maintains a clear qualitative approach to the definition of material risk takers, however we believe that some further specifications are needed along with some proportionality elements also in order to avoid misleading results.