📢 EACB Comments on SRB operational guidance for banks on resolvability self-assessment The EACB welcomes the SRB initiative to enhance transparency in supervisory policies through its operational guidance for banks on resolvability self-assessment. While we appreciate the effort to create a structured and harmonized framework, we have identified several key concerns that require further clarification: 🔹 Ambiguities in definitions – Terms like “significant concentration” and “material liabilities” regarding MREL eligible criteria have not been clearly identified in the operational guidance. 🔹 New Burdens for Banks – The proposed Excel-based template should be improved to allow banks the submission of meaningful input. 🔹 Impact on MREL Policy – The guidance introduces a series of new far-reaching expectations that appear to hint to the MREL policy as part of this consultation. Most of the proposed changes raise serious methodological questions and have far reaching consequences for the industry. 🔹 Proportionality & Usability – The granularity of assessments should better reflect diverse banking models, and the self-assessment template should be more user-friendly. More details are available in our position paper ➡️ https://lnkd.in/eTUhNmFQ #Banking #Finance #CooperativeBanks #Resolvability #EACB #MREL #Regulation
