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    SRB Issues Blueprint for Review of Crisis Management Framework

    May 18, 2021

    SRB issued a bi-annual note aimed at reporting to the Eurogroup on the progress of SRB activities in the areas of resolution planning, resolvability, and minimum requirement for own funds and eligible liabilities (MREL); the latest policy developments; and the Single Resolution Fund. SRB also published a blueprint on key considerations for the review of the crisis management and deposit insurance framework in EU.

    The blueprint on review of the crisis management and deposit insurance framework highlights that, in any reform of the crisis management and deposit insurance framework in EU, the completion of the Banking Union must be a priority. The European Deposit Insurance Scheme (EDIS) is indispensable to enhance financial stability, to overcome the sovereign-bank doom-loop, and to avoid financial fragmentation in the Banking Union. As long as there is no full-fledged EDIS, the originally envisaged third pillar, the Banking Union will remain incomplete and exposed to financial stability issues. The review should enshrine the hybrid model of EDIS into law, but with a time-bound transition period (for example, five years) toward full mutualization or steady state. In the interim period, SRB could use transfer tools at the Banking Union level (the combined use of Single Resolution Fund and Deposit Guarantee Scheme could be explored) to find potential acquirers, maintain the franchise value of failing banks under the SRB remit, and play a coordinating role  in the application of national Deposit Guarantee Scheme alternative measures. In the steady state, SRB should act as the central authority with powers to manage all bank failures in the Banking Union, handling both EDIS and the Single Resolution Fund.

    The bi-annual note on SRB progress highlights that SRB is in the concluding phase of the 2020 resolution planning cycle. Despite the challenges connected to COVID-19 outbreak, SRB kept the 2020 cycle on track and has recently started the 2021 resolution planning cycle. with respect to the minimum requirement for own funds and eligible liabilities (MREL) instruments issued in the UK, SRB will consider liabilities governed by UK law without a contractual bail-in recognition clause as eligible for MREL, if they otherwise satisfy applicable MREL criteria and were issued on or before November 15, 2018. This exemption will apply until June 28, 2025 to ensure alignment with the prudential grandfathering of the requirement to introduce contractual recognition clauses in own funds instruments (as per Article 494b CRR). Furthermore, within the existing legal framework, SRB has enhanced its approach to the Public Interest Assessment by the consideration of systemic-wide events in resolution planning, which will be applied in 2021. Going forward, SRB will work to deepen the analysis on the Public Interest Assessment dimensions related to critical functions at regional level and the protection of covered depositors; work in these areas will be completed before the 2022 resolution planning cycle. SRB is also preparing, among others things, the Backstop Facility Agreement, the Parallel Facility Agreement, and the termination of the Loan Facility Agreements.

     

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    Keywords: Europe, EU, Banking, Single Resolution Fund, SRF, Resolution Planning, MREL, Crisis Management Framework, Deposit Insurance, Resolution Framework, EDIS, SRB

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