BBA has commented on proposals for an EU framework for bank recovery and resolution. It says the new European supervisory framework will be important in delivering more consistent high-level supervision. It says a European dimension will be an important component of an international framework for crisis management but that recovery and resolution tools must be used coherently in all jurisdictions. It encourages mutual co-operation between EU and third country regulators. The response comments that the regulatory reform agenda is already comprehensive and advanced, whereas crisis management plans generally are not. It notes the importance of application of the framework at group level and the need to recognise proportionality when deciding on measures to apply. It also notes there are limits to planning that should reasonably be expected. Finally, it cautions against duplication of existing measures and notes its concern about the economic impact of the proposals, which it thinks has not been fully assessed. (Source: Technical details of a possible EU framework for bank recovery and resolution: Comments from the British Bankers’ Association)