The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the EBA Discussion Paper Application of early intervention measures in the European Union according to Article 27-29 of the BRRD.
The overlaps of supervisory powers identified in the discussion paper and the conditions for applying them, but further still the restraint of the supervisory authorities in applying the EIMs outlined in the discussion paper place a question mark to the necessity of EIMs. In any case there is at least no mandatory reason to reinforce, respectively to amend the legal text of the BRRD. The most important aspect is that authorities are able to respond in a proportional, flexible and tailored manner to the circumstances of the individual institution if crisis situation arise and not whether and how many EIMs have been applied.