66. For the positions for which the exemption is sought, institutions should indicate whether they are positions of type A or positions of type B in accordance with the specifications in the paragraphs below. Positions of type A are positions for which there is the presumption that they are of a structural nature, while positions of type B are positions for which a deeper analysis to assess the structural nature is needed.
67. The categorisation into positions of type A or positions of type B is meant to support the competent authority in analysing the application of the institution; in particular, such categorisation is meant to support supervisors in assessing whether the conditions that positions should meet for being suitable for the exemption are actually met, and represents a minimum level of granularity into which such positions need to be subdivided by the institution.
68. The categorisation into positions of type A or positions of type B is based both on the EBA’s view that
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