Your paper requested comments on your general approach and on 3 specific aspects of treasury management. We have not commented on one of these items, the classification of associations for treasury management purposes, believing this to be a matter of governance outside the scope of our understanding of your regulatory process.
However we would expect the classification to reflect an appropriate level of knowledge and understanding of treasury management at each association. In this context it is worth noting that the requirements of MiFID (Market in Financial Instruments Directive) when implemented next year will put a requirement on the providers of swaps and derivative instruments to assess the suitability and appropriateness of these instruments for their customers.
