Publication date: 11 March 2016
The EBF welcomes the EBA consultation paper on Guidelines (GL) on ICAAP and ILAAP information collected for SREP purposes. The guidelines provide useful additional insight on supervisory expectations regarding the content of ICAAP/ILAAPs and how National Competent Authorities (NCAs) expect firms to demonstrate their adherence to capital and liquidity adequacy standards. Having detailed guidance on the required content of an ILAAP and ICAAP is vital to ensuring the consistency and comparability of ILAAPs and ICAAPs, allowing supervisors to consistently assess their reliability. Furthermore, we welcome the fact that the EBA draft guidelines on ICAAP and ILAAP information collected for SREP purposes recognise that the ICAAP and ILAAP are internal processes. We would like to emphasise the need to maintain the ability for banks to have a flexible approach to their capital planning.