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IBFed Response on BRRD Article 55 - Contractual recognition of bail-in

3 May 2016

The IBFed supports the Financial Stability Board’s (FSB) Key Attributes for Effective Resolution Regimes for Financial Institutions and regards the BRRD as generally a faithful implementation of these principles. We recognise that the requirements under Article 55 are intended to facilitate the cross-border recognition of resolution action, specifically bail-in. However, we note with concern that the rules apply to a very broad scope of liabilities, including liabilities arising out of contractual arrangements which are clearly unsuited to write-down or conversion via bail-in, and which are unlikely to contribute to a recapitalisation of a bank under resolution.

Please read the full response via the link below.

IBFed Response on BRRD Article 55 - Contractual recognition of bail-in
 
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