Bank resolution planning

DNB determines in advance how it will intervene in a bank that gets into difficulty. The bank must remove any obstacles to such intervention. This process is known as “resolution planning”.

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Resolution planning ensures that both we and the banks are better prepared for a possible crisis, thereby reducing the impact of a bank failure. DNB draws up a resolution plan for each bank.

Resolution plan

The resolution plan describes how DNB may intervene if a bank is in difficulty. It includes:

  • resolution strategy
  • a description of how operational and financial continuity is guaranteed
  • the amount of loss-absorbing capacity a bank must hold
  • any obstacles to the implementation of the resolution strategy.

Resolution strategy

A resolution strategy includes the following points:

  1. Will a bank be allowed to go bankrupt or will DNB take it into resolution? We determine this by means of a “public interest test” in which we assess the impact of a bankruptcy on the financial system or the economy as a whole. For example, there may be so many payment or savings accounts that DNB considers this function to be critical. The impact on other banks, and hence financial stability in the Netherlands, may also be too great. In that case the bank qualifies for resolution.
  2. If a bank qualifies for resolution, DNB describes the preferred resolution tool. Generally, the bail-in tool is appropriate for the largest banks, while a sale is the most likely option for smaller banks.

Continuity

Operational and financial continuity is crucial in order to implement the resolution strategy. The resolution plan states, for example, which ICT systems must continue to operate. Sufficient liquidity must also be guaranteed during and after resolution.

Loss-absorbing capacity (MREL/TLAC)

If a bank fails and goes into resolution, it must have sufficient “loss absorbing capacity”. This is necessary to absorb losses and recapitalise the bank with the aid of the bail-in tool. Since 2017 resolution authorities have been able to set minimum levels of equity and eligible liabilities for European banks as part of the MREL requirement. As of 1 January 2019, globally systemically important banks (G-SIBs) must comply with the total loss absorbing capacity (TLAC) standard of the Financial Stability Board (FSB), an international consultative body. Read the download MREL/TLAC. 

Obstacles to resolution

Finally, DNB assesses whether the resolution plan is feasible in practice or whether there are obstacles, such as an overly complex structure, non-marketable assets or an inability to supply certain information rapidly to DNB. If DNB identifies an obstacle, the bank must eliminate it to ensure the feasibility of the resolution strategy.