EBU Single Rulebook Q&A 4 November 2019 2019_4983 MREL subordination for smaller banks

Is the subordination requirement for the MREL of smaller banks (i.e. that are not G-SII or part of a G-SII, top tier banks nor banks subject to Article 45c(6)) subject to the limit of the prudential formula referred to in Article 45b(7)?