GBIC welcomes the decision to update the SREP Guidelines. We also agree with the overarching objectives, namely (a) to increase convergence of practices followed by competent authorities across the EU, and (b) to align the SREP Guidelines with other relevant EBA guidelines and technical standards.
Nevertheless, the draft version of the Guidelines
contains specific provisions that go further than the EU Directive
(CRD). In addition, the scope of provisions set out in the Guidelines
has been expanded yet again. We fear that this could further eclipse
proportionality issues under Pillar 2.
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