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GDF Response to the EBA Consultation on Redemption Plans under MiCAR
GDF has worked with its members in the MiCA Working Group to provide a constructive assessment of additional areas where the EBA and NCAs can provide additional guidance when implementing the Technical Standards.
Through this process the Working Group identified key areas that may require further drafting consideration or additional guidance for purposes of clarity, proportionality, and effective implementation. The core areas identified are:
1) Further Specificity on ‘What Good Looks Like’
2) Support for Proportionality on Implementation; and
3) Greater Specificity Regarding Costs.
