Response to consultation Paper on Guidelines amending Guidelines EBA/GL/2022/01 on improving resolvability for institutions and resolution authorities

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Q2. Do you have any comments on the list of questions to banks included in the self-assessment as set-out in para 125-126?

The EACB members are of the view that banks should not be expected to assess the authorities’ role in the execution of the strategy. If – with reference to the para. 125 (a) – banks are expected to give an assessment of the role of the resolution authority in the execution of the strategy, we would like to point out that the basis of this assessment needs elaboration since it is perceived to be a sensitive topic. In this regard, we are of the view that the EBA (in its role as an authority) should provide all banks with a template for the self-assessment to ensure clear guidance and a level playing field.
Regarding recovery planning, before the banks are expected to describe the resolution capabilities in relation to the recovery planning as outlined in para. 124 (e), the competence between the supervisory and the resolution authority should be clarified. In general, EACB would welcome a clarification of the change of competence in the transition from recovery to resolution.

Q3. Do you have any comments on the proposal to require authorities to communicate a multiannual testing programme?

In our opinion, banks should maintain the right – and responsibility – to create their own testing programmes. In other words, there is no need for authorities to communicate detailed and rigid programmes to the banks.

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Name of the organization

European Association of Co-operative Banks (EACB)