ESBG has recently shared its feedback with the Single Resolution Board (SRB) on its future strategic review which aims to enter into a new era after the completion of the construction phase. This phase was marked by the build-up of the Single Resolution Fund (SRF) and by the introduction of tools improving the resolvability. As part of the second phase, priority will be given on operationalisation with a focus on the resolution plans.
In its consultation response, ESBG has focused on two main elements. Regarding the first part which focuses on how the SRB consultation process can be enhanced, ESBG is of the opinion that both the banking sector and the Resolution Authorities would benefit from a wider framework for SRB consultation. Currently, the number of consultations does not cover the wide spectrum of expectations. It will also be desirable to promote an active participation of the banking industry in advance of implementing modifications on regulations they are subject to. ESBG also believes that banking associations are insufficiently involved in some consultations (e.g. SRB consultation on SRF contributions). A bundling of feedback by associations would be more expedient, as this would avoid receiving hundreds of identical comments for the SRB. Finally, considering the too-short consultation periods in the past (e.g. for MREL Policy), ESBG recommends to extend the deadlines.
On the second part, ESBG commented on how SRB could improve transparency and interactions with the banking industry. ESBG confirms that, in terms of transparency, a great progress has been made over the years; however, a balance must be struck between transparency and over-information. The latter makes reaching the knowledge more difficult; hence ESBG recommends the SRB to add a summary of the most important key points in front. In terms of interactions, ESBG members really appreciate the participation in the industry dialogue meetings initiated by Dr. König which should continue to take place physically. Also, the SRB should, similar to the ECB banking supervision, gradually translate the contents of the website into all official languages and also make important documents, such as policies, expectations or guidelines, available in these languages. Finally, with regards to formal communication on resolution cases, ESBG advocates that confidential information sessions for banks’ head of resolution planning and IRTs could be helpful for knowledge sharing amongst peers.
