The EACB welcomes the opportunity to comment on the draft EBA Guidelines on the delineation and reporting of available financial means (AFM) of Deposit Guarantee Schemes (DGS).
We appreciate the EBA’s efforts to provide a clarification in relation to the interpretation of the concept of AFM ahead of adopting relevant amendments in the Deposit Guarantee Schemes Directive (DGSD). The proposed delineation does not raise our concerns and we see the advantages of having in place such specification. It would be particularly beneficial from the perspective of avoiding the following risks: raising little or no contributions from the industry, raising the contributions from the industry on an unequal basis, lack of clarity and comparability of DGSs.