The Commission has published its proposals for a Directive to ensure that Member States use compatible recovery and resolution measures (“living wills”) when dealing with failing financial institutions. The objective is to facilitate home-host cooperation arrangements in cross-border crises. The proposals are divided into:

  1. prevention;
  2. early intervention; and
  3. resolution.

The Commission wants to ensure crises are averted if at all possible, but that if a wind-down of a bank’s operations is necessary it can be done in an orderly manner. Under the proposals:

  • banks must prepare recovery plans;
  • authorities must prepare resolution plans for banks;
  • authorities must assess banks’ plans and require changes where appropriate; and
  • banks will be allowed to propose intra-group arrangements for support.

Supervisors will be able to implement early intervention measures when they think a bank will not be able to meet its capital resource requirements and can also appoint a “special manager” to a bank for a limited period. Where all else fails and the supervisor decides resolution is essential, the main regulatory tools comprise:

  • business sale;
  • bridging institution;
  • asset separation; and
  • bail-in.

The proposals also deal with the possibility of requiring resolution funding, whereby banks may have to fund a proportion of the costs of resolution. (Source: EU Framework for Bank Recovery and Resolution (June 2012))