Recital 4

(4)The amendments to Implementing Regulation (EU) 2015/2197 do not involve significant changes in substantive terms, but merely apply the methodology already established in that Regulation to updated data series. In accordance with Article 15(1), second subparagraph, of Regulation (EU) No 1093/2010 of the European Parliament and of the Council ³ , EBA has therefore neither conducted an open public consultation on the draft implementing technical standards on which this Regulation is based, nor analysed the potential related costs and benefits, considering that such a consultation or analysis would be highly disproportionate in relation to the scope and impact of the draft implementing technical standards concerned. EBA requested the advice of the Banking Stakeholder Group established in accordance with Article 37 of Regulation (EU) No 1093/2010,