SRB Issues Operational Guidance on Separability of Banks During Crisis

The operational guidance helps banks by providing more detail on how to concretely deliver the relevant information and analysis through the separability analysis report and an operational document called the transfer playbook. Separability is a broad concept relevant to all resolution strategies. Separability is defined as the bank’s ability to implement a transfer of legal entities, business lines, or portfolios of assets and liabilities at short notice to a third party. Separability allows SRB to execute, together with the national resolution authorities, a market transaction within a reasonable amount of time, to ensure the resolution objectives through the bank’s transfer, in due course, to a private owner or through an orderly wind-down. It is particularly relevant for banks for which the resolution strategy envisages a transfer tool, such as sale of business, asset separation tool, and the bridge institution tool. This concept allows SRB to access the necessary information and analysis from banks to make full use of resolution tools should a bank get into difficulty and to ensure, for example, that different arms of a banking group can be separated out with appropriate solutions applied. This will help ensure financial stability. 

In addition, to comply with the expected deadline, separability work to operationalize partial transfer tools is also a general working priority during the 2022 resolution planning cycle for relevant institutions. Principle 7.2 in the Expectations for Banks document is particularly relevant for banks for which the resolution strategy envisages a transfer tool. It sets out the expectation for banks to deliver separability analyses by the end of 2023. In line with the Expectations for Banks, while the operational guidance is general in nature, its application to each bank may be adapted to individual specificities, taking into account the proportionality principle and based on a dialog between each bank and its Internal Resolution Team. The guidance is not exhaustive and may be subject to further SRB communications related to resolvability requirements for banks, for instance, to reflect any remaining alignment with guidelines at the EBA level on resolvability and transferability once these are finalized.

Related Links

• Press Release on Cooperation Agreement
• Press Release on Guidance
• Operational Guidance (PDF)
• Expectations for Banks

Keywords: Europe, EU, Banking, Resolution Planning, Banking Union, Switzerland, Resolution Framework, Cross-Border Resolution, Separability Analysis, Transfer Playbook, SRB