• Past performance of receiving entity can be used for assessment.
• Reputational impact of allowing a subsidiary to fail should be considered.
See general comments in attached document.
• Maintaining BAU capital limits e.g. large exposures will limit the amount of group support that can be provided.
See generalcomments in attached document.
• As above, authorities should consider allowing temporary breaches of ratios to enable provision of group support to the extent required by receiving entity.
See generalcomments in attached document.
• See comments for questions 3 and 4
See generalc omments in attached document.
• The rules may encourage regional funding models vs. centralised funding models. This needs to be considered in context of appropriate resolution strategy (ie SPE or MPE)