Question ID
2026_7777
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
art. 2.2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
art. 2.2
Type of submitter
Resolution authority
Subject matter
Article 2.2 Reporting by credit institutions permanently affiliated to a central body
Question

In a particular case of an atypical structure of credit institutions permanently affiliated to a central body when:

a) none of them is a resolution entity and the central body is a liquidation entity

b) the cohort of institutions does not formally qualify as a group nor as a resolution group due to their atypical association

c) the cohort is prudentially supervised individually at the level of the central body and in aggregate at the cohort level (our regulations use the term aggregate level, not the consolidated level)

d) in case that the central body is liquidated, the whole cohort can no longer function and has to be dissolved, thus, for resolution purposes, the whole construction can be treated as a single liquidation entity.

      In this case, is it correct, to read art. 2.2 in conjunction with recital no. 4 and ask the central body to report the templates on an individual basis and by that understand the aggregate level of the whole cohort?

Background on the question

In a particular case of an atypical structure of credit institutions permanently affiliated to a central body when:

a) none of them is a resolution entity and the central body is a liquidation entity

b) the cohort of institutions does not formally qualify as a group nor as a resolution group due to their atypical association

c) the cohort is prudentially supervised individually at the level of the central body and in aggregate at the cohort level (our regulations use the term aggregate level, not the consolidated level)

d) in case that the central body is liquidated, the whole cohort can no longer function and has to be dissolved, thus, for resolution purposes, the whole construction can be treated as a single liquidation entity.

      In this case, is it correct, to read art. 2.2 in conjunction with recital no. 4 and ask the central body to report the templates on an individual basis and by that understand the aggregate level of the whole cohort?

Submission date
Final publishing date
Final answer

Recital 4 of Commission Implementing Regulation (EU) 2025/2303 states that it is necessary to ensure that resolution reporting is not impeded by prudential waivers or by resolution groups not subject to prudential consolidation requirements. 

In this regard, recital 4 is not relevant for the case at stake. Based on the information provided in the question, provided that the credit institutions permanently affiliated to a central body are not subject to simplified obligations, Article 2 of the CIR 2025/2303 would apply. To the extent that there is not any resolution group, Article 5 of the CIR 2025/2303 does not apply.

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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