EBF comments on the EBA consultation paper (CP): draft guidelines
Publication date: 25 October 2016
Question 1: Is the scope of application of the guidelines appropriate and sufficiently clear?
Yes the scope of application of the guidelines is considered clear and appropriate.
Question 2: Is the date of application of the guidelines of 1 January 2018 appropriate?
Yes, assuming that IFRS 9 application date in the EU will be the same.
Question 3: Please provide any comments you may have on the appropriateness of the proposed proportionality approach.
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