2018年-EBA欧洲银行管理局_EBA_Report_on_the_functioning_of_resolution_colleges_July_2018_17页_515kb

EBA Report on the Functioning of Resolution Colleges in 2017 Summary

Core Content

This report, published by the European Banking Authority (EBA) in July 2018, evaluates the functioning of resolution colleges across the European Union (EU) during the 2017 resolution cycle. The EBA monitors the activities of these colleges to ensure they operate efficiently, effectively, and consistently, as mandated by the Bank Recovery and Resolution Directive (BRRD). The report focuses on three main areas: organisational aspects, quality of discussions, and deliverables such as joint decisions on resolution plans, MREL, and measures to remove impediments to resolvability.

Main Findings and Progress Achieved

Organisational Aspects

• Most resolution authorities are in their third year of operation.
• Significant time and resources were invested by GLRAs in organizing and running college meetings.
• Host authorities generally contributed well, supporting the college's work through active participation and targeted presentations.
• Improved bilateral engagement between GLRAs and host authorities helped facilitate better discussions and joint decisions.
• For third-country banks, six resolution colleges were held via conference calls, marking progress in information sharing, though no formal joint decisions were made.

Quality of Interaction

• There was an overall improvement in the level and quality of discussions compared to 2016.
• Host authorities became more active in questioning and challenging the GLRA and other participants.
• The quality of presentations and discussions varied across colleges and authorities, but the EBA encourages the adoption of best practices from supervisory colleges.

Deliverables

• Most colleges achieved joint decisions on resolution plans and resolvability assessments for the second consecutive year.
• The resolution plan and resolvability assessment are central to the resolution-planning process, detailing the preferred strategy, critical functions, and operational arrangements.
• Progress was noted in identifying impediments to resolvability through data collection, self-assessment, and engagement with banks.
• Joint decisions on MREL were reached for the first time since the BRRD's implementation, indicating a step forward in ensuring loss-absorbing capacity for banking groups.

Areas for Improvement

Organisational Aspects

• Annual resolution planning cycle: Five out of 13 monitored colleges were postponed to 2018, leading to some meetings falling outside the 12-month window.
• Minutes circulation: Only four out of 13 GLRAs circulated minutes of the college meetings, which are essential for clarity and accountability.
• Circulation of information and materials: Authorities were encouraged to share documents in advance of meetings, including bank templates and presentations.
• Timely contributions: The EBA urged host authorities to meet deadlines to reduce the burden on organizing authorities.

Quality of Interaction

• Interplay between recovery and resolution: There was a lack of in-depth discussion on how recovery plans impact resolvability, despite some progress in information sharing.
• Presentation quality: The EBA recommended that GLRAs improve the quality of presentations and consider adopting best practices observed in supervisory colleges.
• Bank participation: Some banks' representatives lacked the necessary seniority or expertise, resulting in less effective discussions.

Deliverables

• Operational aspects of resolution plans: Many plans still required improvement in key areas such as bail-in execution, funding and liquidity, and access to financial market infrastructures (FMIs).
• Critical functions: Discrepancies remained between the assessments of criticality by home and host authorities, raising concerns about consistency and the need for home authorities to consider host-specific factors.
• Scope of plans: Some plans lacked detailed information on operations outside the home jurisdiction, which is essential for a credible resolution plan.
• Resolution strategies: While some colleges began considering variant strategies, this process was not yet widespread.
• Removal of impediments: No joint decisions on measures to remove substantive impediments were made, despite progress on certain areas like MREL-eligible debt and contractual stays.
• MREL framework: The MREL framework is not yet fully finalised, and eligibility criteria remain unclear for some banks, leading to uncertainty for investors and challenges in funding planning.

Key Recommendations for 2018

1. Bail-in execution policies: The EBA will focus on developing policies and alternatives to bail-in tools.
2. Interplay between recovery and resolution: Authorities should enhance discussions on the link between recovery and resolution plans.
3. Monitoring of removal of impediments: The EBA recommends the use of consistent monitoring tools and clearer work plans to increase accountability.
4. MREL framework: MREL should be set at the entity level, with clear eligibility criteria and consistent application across banks and authorities.
5. Circulation of minutes and information: Authorities must ensure timely circulation of minutes and supporting materials to maintain transparency and accountability.

Concluding Remarks

The EBA acknowledges the progress made by resolution colleges since the BRRD's implementation, noting that they are largely compliant with the Delegated Regulation. However, it emphasizes the need for continued improvements in operational aspects, such as compliance with annual cycles, timely information sharing, and the finalisation of the MREL framework. The EBA encourages all relevant authorities to work collaboratively to ensure the effective operationalisation of resolution strategies and the removal of impediments to resolvability.