The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the EBA Consultation Paper on Draft Regulatory Technical Standards on specifying the methodology to be used by resolution authorities to estimate the requirement referred to in Article 104a of CRD V (Pillar 2) and the combined buffer requirement for resolution entities at the resolution group consolidated level for the purpose of setting MREL under BRRD Article 45c(4).
Indeed, we see that the MREL calibration needs to take due account of the fact that going-concern capital requirement may be set at group level with a perimeter that differs from the resolution group’s perimeter: if not appropriately catered for this could lead to inappropriate estimation of risks and consequent requirements within the resolution group. At the same time, we believe that certain elements of the calculation method laid out in the draft RTS appear to be conflicting with such aim and require clarification.