Publication alert: SRB - Operational Guidance for Banks on separability for transfer tools
We communicate that the Single Resolution Board (SRB) has published the Guidance on Separability of Banks for transfer tools.
1. Context
In April 2020, the SRB published the Expectations for Banks (EfB) document that sets out its expectations towards banks under its remit in order to ensure an appropriate level of resolvability and It also sets out the expectation for banks to deliver separability analyses by the end of 2023.
In this context, the SRB has published the Operational Guidance on Separability. This guidance provides more detail to banks on how to concretely deliver the relevant information and analysis, namely through an analytical document known as the separability analysis report (SAR), and an operational document, the transfer playbook.
2. Main points
SAR. Banks are expected to deliver a SAR, which is an analytical document intended for the resolution authority and for potential investors. It should contain the following parts:
- A perimeter identification. The institution should present in this section the proposed transfer perimeter, its composition and the main arguments for its proposal.
- Separability assessment. The institution should assess the interconnections, which can be financial, legal, operational or business interconnections, with the perimeter established. The institution should identify potential barriers or constraints to a smooth transfer implementation following the analysis of the interconnections and of other separability aspects.
- Market interest and capacity. The institution should provide and assess a list of potential buyers and their suitability based on the perimeter, their financial strength, among other criteria.
- Bank’s information capabilities. The institution should provide a self-assessment of its capabilities to provide accurate and timely information on the transfer perimeter in resolution planning.
Transfer playbook. In order to further operationalise and demonstrate the ability to implement the transfer of the proposed perimeter (including any perimeter shifts), the bank should also produce a transfer playbook. This will be used as an operational document intended for use by the institution itself, listing the processes needed, organisational units involved and concrete operational steps. The main elements of these playbook should be: i) governance, ii) timeline for implementation, iii) mitigation strategies for barriers and potential impediments to execution, and iv) communication with all the stakeholders.
3. Next steps
Banks must present either a preliminary analysis of the SAR or the SAR and transfer playbook by December 31, 2022.