ESBG and its members responded recently to a consultation on the Single Resolution Board “expectations for banks".
Below is the link to the completed questionnaire to the SRB consultation. A general outline follows, which provides ESBG's position and specific stance on certain related topics related to the consultation.
Submitted to SRB: 4 December 2020
>> .pdf of consultation response
While many principles in the “expectations for banks" document are similar to requirements and expectations of the resolution framework of the recent past, ESBG argues that it significantly increased granularity and introduced additional actions compared to the current market practices. These requirements and this course of action must be carefully evaluated and considered in order to identify potential new compliance areas, impediments that may require resolving, and potential improvements to work already performed in recent years surrounding resolvability. ESBG will remain vigilant and continue to communicate key concerns identified by the community of association members to the EU Singe Resolution Board. Additional or complementary guidance would be appreciated considering the expectations, the dimensions including the necessary steps and initiatives needed to ensure resolvability e.g. operational continuity. In addition, some of the resolvability dimensions seem to overlap with the conditions included in the Multiple Points of Entry (MPE) action plan and the resolvability progress report provided to the IRT.
Summary of positions on the dimensions: