Early intervention measures, conditions for resolution and funding of resolution action (BRRD3)

The Dutch Banking Association shares its views on the Crisis Management and Deposit Insurance (CMDI) proposal which was published on April 18th 2023. The Dutch Banking Association and its members recognise the great importance of an effectively functioning Crisis Management & Deposit Insurance (CMDI) Framework for the adequate unwinding of banks through resolution or bankruptcy.

On April 18th, the European Commission presented four new legislative proposals with an aim to reinforce the European Unions crisis management and deposit insurance (CMDI) framework. Over the last decade, significant improvements have been achieved as banks have built up Minimum Requirements for Own funds and Eligible Liabilities (MREL) and Total Loss Absorption Capacity (TLAC) buffers.

The EAPB supports the objectives of the CMDI review which aims at strengthening rules for handling bank failures while protecting depositors. It is important however that the review duly considers the business model of promotional banks and other public banks which primarily fund the public sector and SMEs.

These comments have been prepared by the French Banking Federation (FBF) as a reaction to the European Commissions (EC) proposal to review the EU crisis management and deposit insurance (CMDI) framework, which includes four legislative texts Daisy Chains, the Bank Resolution and Recovery Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the Deposit Guarantee Scheme Directive (DGSD).

Banking Union: Review of Crisis Management and Deposit Insurance framework (CMDI) Executive summary Finance Denmark welcomes the underlying objective of the Commission’s proposal for the Review of the Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims at broadening the application of resolution tools in crisis management at European and national level for all European banks, regardless of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Introduction. We fully support the BU. In this sense, we think that there is still room for improvement on the resolution framework, and this proposal goes in the right direction. However, we think that it is key to reach an agreement on the third pillar (EDIS).

The National Association of German Cooperative Banks (Bundesverband der Deutschen Volksbanken und Raiffeisenbanken e.V. BVR) is in favour of improving crisis management for credit institutions. However, we are afraid that this welcomed goal will not be achieved by the amendments proposed with the CMDI Review.

The German Banking Industry Committee (GBIC) welcomes the goal of improving crisis management for credit institutions. However, the changes proposed by the European Commission would considerably impair the performance of the well-established national deposit-based guarantee schemes and call into question the structure of the German banking market. The legislative proposal is therefore rejected in its entirety.

Finance Finland (FFI) welcomes the efforts to improve the Banking Unions crisis management tools. The Commissions proposal has many good suggestions which help improve crisis resolution, such as increasing information exchange between supervisory and resolution authorities.

The Central Association of German Crafts represents the interests of around one million mainly small craft businesses with more than 5.6 million employees in Germany. As funding opportunities for our members are closely linked to the smooth functioning of the financial system, we are participating in this consultation.

Filed in German · English published by the European Commission

The Italian experience and, in particular, FITD interventions have shown in real cases that the current CMDI framework can lead to effective banking crisis management, with the use of all tools and FITD private resources.

August 2023 FGDR Contribution to the EU Commission Consultation for a Renewed CMDI Framework FGDR welcomes the initiative of the Commission to ask for feedback over its proposal for a new EU CMDI framework. Comments below only reflect FGDR’s views, based on its understanding of the proposal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ABI welcomes the Commissions effort to optimize the Crisis Management and Deposit Insurance framework by amending three legislative texts, namely the Banking Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism regulation (SRMR) and the Deposit Guarantee Schemes Directive (DGSD).

The ABBL welcomes the underlying objective of the Commissions proposal for a Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims notably at: Broadening the application of resolution tools in crisis management at European and national level including for smaller and medium-sized banks; Extending the use of privately funded safety nets (i.e.

From our Associations point of view, we would like to comment on two critical points in the CMDI package as follows: 1. It is planned to amend Art. 31(2)(d) BRRD in a way that the protection of all depositors is made a resolution goal in the future (full protection of all depositors) and not only the protection of depositors covered by the deposit protection schemes. 2. Draft Art.

We fully support the objective to strengthen depositor protection and confidence as stated in the Commission's draft legislation. However, the path taken by the EC to achieve these aims is the wrong one. 1. Extension of MREL scope This is particularly true for the proposed extension of the scope of application to smaller and medium-sized banks.

Resolution scope: the EU Commission is undertaking far reaching adjustments in the BRRD, specifically regarding the extension of the application of the resolution mechanism, including small and medium-sized institutions. Thus, the EU Commission aims for a fundamental shift, as resolution was once conceived as a response to "too big to fail", not a concept for small and medium-sized savings and retail banks.

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the proposal for a Directive of the European Parliament and of the Council amending Directive 2014/59/EU as regards early intervention measures, conditions for resolution and financing of resolution action. Please find attached our considerations.

BRRD Public Interest (Art. 32 (5) in conjunction with Art. 31(2) and Art. 2(1) No. 35 BRRD draft) The proposed approach of making resolution the standard for crisis management in the banking sector is foreseeably more bureaucratic and financially burdensome, especially in the case of small and medium-sized institutions.