On 23 December 2012, ISDA published a letter sent in response to the EU Commission’s Consultation on a possible recovery and resolution framework for financial institutions other than banks. ISDA’s response focuses mainly on RRP for Central Clearing Counterparties (CCPs).  It believes that a common resolution framework should apply to all FMIs (and not just […]

Introduction On 21 December 2012, the European Commission published a summary of the replies received to its October 2012 consultation on the recommendations of the high-level expert group on reforming the structure of the EU banking sector (the “Liikanen Group”).  It also published links to individual responses. In total, the Commission services received 89 responses […]

Introduction On 5 December 2012, the European Insurance and Occupational Pensions Authority (EIOPA) published its response to the EU Commission Consultation on a possible recovery and resolution framework for financial institutions other than banks. RRP for Insurers EIOPA supports the principle of RRP for insurers, but emphasises that (re)insurers are believed to have a more […]

This is a link to an excellent opinion piece in the FT on the recent announcement regarding EU banking union. The first steps towards banking union announced last week were widely lauded as representing a significant in-principle agreement.  The truth is that this principle was agreed two years ago.  Unfortunately, what happened last week was […]

On 18 December 2012, the Financial Stability Board (FSB) published a press release regarding responses received to its 2 November 2012 consultation on Recovery and Resolution Planning, together with links to the responses of the following institutions: Association of British Insurers Barclays BNP Paribas British Bankers’ Association Credit Suisse Deutsche Bank Federation Bancaire Francaise FirstRand […]

Introduction On 14 December 2012, the European Banking Authority (“EBA”) published its opinion on the recommendations of the High-level Expert Liikanen Group on reforming the structure of the EU banking sector. The final report of the Liikanen Group was published on 2 October 2012 and made the following recommendations:  mandatory separation of proprietary trading and […]

On 14 December 2012, the European Council published its conclusions regarding the steps necessary to complete economic and monetary union (EMU).  These include: the need for the rapid adoption and implementation of the single supervisory mechanism (SSM); the agreement on the terms of the Recovery and Resolution Directive (RRD) and the Deposit Guarantee Schemes Directive […]

Introduction On 11 December 2012, the Geneva Association, a think-tank for the insurance industry, published a cross-industry analysis comparing the 28 Global Systemically Important Banks (G-SIBs) to 28 of the world’s largest insurers on indicators of systemic risk. The analysis studied 17 indicators that are regarded as being comparable between insurers and banks to provide […]

Introduction On 10 December 2012, the Federal Deposit Insurance Corporation (FDIC) and the Bank of England (BOE) published a joint strategy paper on the resolution of globally active, systemically important, financial institutions (G-SIFIs). Broadly speaking, there are two main approaches to the resolution of G-SIFIs: “Single point of entry” (or “top down”) resolution pursuant to […]