On 17 September 2013, the European Banking Federation (EBF) published a position paper entitled “EBF Positioning on the Principles underlying the Single Resolution Mechanism”. The paper includes a high-level discussion on the European Commission’s recent announcement of a Single Resolution Mechanism (SRM) as a complement to the Single Supervisory Mechanism (SSM) within the project of the Banking Union. Two concerns worth noting are:
- the EBF believe that the target fund should be built up over 15 years rather than 10 ten years as proposed which appeared far too long to begin with; and
- the EBF do not agree that member states should have the flexibility to apply exclusions from bail-in for any eligible liabilities – this would include the ability to exclude derivatives from bail-in. This does seem to be a good idea as it helps create a level playing field and avoids a race to the bottom.