The development of resolution regimes for banks constitutes a major step in the regulatory responses developed since the financial crisis of 2008. In my concluding remarks, I would like to focus on five issues:

THE MOVE FROM POLICY DESIGN TO IMPLEMENTATION

Over the last few months we have witnessed an impressive stream of policy initiatives and reports on resolution issues from various institutional bodies: the European Banking Authority (“EBA”) released its July 2016 Interim Report on implementation and design of the MREL framework (the Minimum Requirements for Own Funds and Eligible Liabilities), the Financial Stability Board (“FSB”) reported in August 2016 to the G20 on the progress of their resolution work, and the Single Resolution Board (“SRB”) set out the details of its tasks and work on resolution planning in its September 2016 Guide.

The focus of the FSB Report was in flagging areas within which further work was needed, such as in matters of liquidity, bail-in, Management Information Systems (“MIS”) and the continuity of access to Financial Market Infrastructures (“FMIs”). The EBA Interim Report meanwhile emphasized its preferred option to change the reference base for the MREL from total liabilities to Risk Weighted Assets (“RWAs”), the need for consistency between MREL calibration and the prudential capital requirements applicable to a bank before and after resolution (also in the approach to the stacking of capital buffers), and the view that mandatory subordination of MREL may improve resolvability. Finally, the SRB's publication of a Resolution Planning manual in September 2016 provided an opportunity to set out a number of relevant aspects of the SRB's approach to resolution planning that had, so far, only been alluded to informally, and to give some indication of its expectations regarding the resolvability of banks.

It is worth mentioning here that, since the October conference, further relevant policy initiatives were made public: in November 2016, The European Commission set out its comprehensive banking reform package, proposing amendments to the Capital Requirements Regulation (“CRR”) and the Directive (“CRD”) and to the Bank Recovery and Resolution Directive (“BRRD”) and the Single Resolution Mechanism Regulation (“SRMR”) to implement the relevant international standards within EU law.