EBF has published its response to EBA on the draft regulatory technical standards (RTS) for bank recovery plans under the bank Recovery and Resolution Directive (RRD). Its key messages include:

  • EBF opposes the requirement for separate recovery plans for each entity within a consolidated banking group, as this would not mirror the group's structure and funding;
  • the information included in recovery plans should reflect the fact that, at that stage, management will still remain in control and the focus would still not be on continuity of significant functions, which is a matter for resolution plans; and
  • recovery plans must be flexible, rather than addressing scenarios which cannot be predicted, and not include automatic triggers.

The Association for Financial Markets in Europe (AFME) has also published its response to EBA's consultation. It highlights broadly the same issues as EBF, and calls for confidentiality of the sensitive information included in the recovery plans. (Source: EBF Response on Recovery Plans RTS and AFME Response on Recovery Plans RTS)