BaFin, along with SRB, is planning to expand the existing “German Internal Resolution Teams” bail-in guidance to include aspects of the SRB minimum data list for bail-in purposes. SRB published a set of documents in mid-August to give operational guidance to banks on implementation of the bail-in tool, including a document on operational guidance on bail-in playbooks. The bail-in playbook is an internal document of banks, establishing a minimum set of objectives, processes, and governance structures to support the implementation of write down and conversion powers by national resolution authorities. Considering the specific guidance of the Internal Resolution Team, the bail-in playbook is expected to include a list with the data points for bail-in purposes.
The list of required bail-in data points is generally based on the minimum list of data points defined by SRB in cooperation with the respective national resolution authority for the purpose of bail-in execution and might be amended by country-specific data requirements. If a bank includes additional data points that have not been previously defined by the resolution authorities, the bank is expected to explain the reason for the inclusion of a specific data point. Other documents published by SRB on implementation of the bail-in tool include a set of questions and answers (Q&A) for publication of bail-in guidance and instructions for bail-in data sets, which are accompanied by an explanatory note. The documents were published as a follow-up to the SRB Expectations for Banks document, which was published earlier in 2020.
Keywords: Europe, Germany, Banking, Resolution Planning, Resolution Framework, Bain-In, SRMR, BRRD, SRB, BaFin
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