GIBRALTAR RESOLUTION AND COMPENSATION UNIT Gibraltar Resolution Planning
GIBRALTAR RESOLUTION AND COMPENSATION UNIT Gibraltar Resolution Planning Framework Industry Dialogue Workshop: Content of Resolution Plans 3 November 2017 1
Today’s Content • Quick recap on Gibraltar's Bank Resolution Structure • Resolution Planning and Actions • Steps for resolution planning • Content of Resolution Plans • Industry Dialogue Workshops • Information for Resolution Plans • Resolution Plans Info Templates • Next Steps • Questions/Comments 3 November 2017 2
Gibraltar's Bank Resolution Structure The FSRCC/RCU are operationally separate from the GFSC 3 November 2017 3
Resolution Planning and Actions Resolution Plan Prepared by RCU with a full set of measures to wind down a failing bank without the knock on effect on the local economy & taxpayer FSRCC Plan Anticipates Resolution Based on exiting plan FSRCC decides upon resolution scheme Bank Falls into trouble 3 November 2017 Existing Recovery Plan is used Recovery fails Bank determined failing or likely to fail Bank enters resolution Bank reorganised 4
Steps for Resolution Planning: RCU Analyse the bank's critical functions Assess whether bank can be wound up under normal insolvency proceeding Review / Update Resolution Plan Phases to be delivered via Industry Dialogue Workshops Determine preferred resolution strategy for bank Address impediments and determine MREL Assess resolvability of bank and identify impediments 3 November 2017 5
Content of Resolution Plans Info from firm required Executive Summary Conclusion of Resolvability Assessment Strategic Business Analysis Information and Communication Plan Preferred Resolution Strategy Financial and Operational Continuity 3 November 2017 Opinion of Institution Info from firm required 6
Industry Dialogue Workshops • Content of Resolution Plans: 3 rd November • Introduction to MREL and MREL setting: 6 th December • Data liquidity template: February 21 st 2018 • Simplified Obligations: February 28 th 2018 • Critical FunctionsShared Services: March 21 st 2018 3 November 2017 7
Information for Resolution Plans • Relevant, accurate and updated information on institutions is crucial in order for resolution authorities to draw up resolution plans and substantiate their resolvability assessment and resolution strategy • Draft Implementing Technical Standards (ITS) have recently been developed by the EBA on the information which institutions must provide to resolution authorities for the purpose of drawing up and implementing resolution plans • The ITS latest amends have been completed following a review of previously published BRRD forms and templates (from 2015), taking into account the recent experiences gained in the areas of resolution planning and supervisory reporting. The new framework is expected to be fully operational by 2019 when resolution authorities will collect information as of 31 December 2018. Thereafter, templates will be collected on an annual basis 3 November 2017 8
Resolution Plans Info Templates • This first block of templates collects general information on an institution. It enables the resolution authorities to map a group and locate and its various entities, identify the main distribution of assets and risk weighted assets, consolidation perimeters, and the main contact points • The second block will be used for a wide range of purposes such as defining the main financial intragroup interconnections within the group, setting and monitoring MREL or implementing bail-in strategies • The final (third) block of templates relates to identifying critical functions, mapping them across group entities and identifying which core business lines, services, financial market infrastructures and information support them. The preservation of critical functions is a central resolution objective and the identification of such functions and mapping across the group is a mandatory task for resolution authorities • A data point model is currently under consideration by the RCU. This will allow for an automated validated collection of data in a secure environment, whilst also significantly adhering to the cost focussed strategy of the Unit. It should also look to minimise the reporting burden for firms as much as possible 3 November 2017 9 Today’s Focus
Next Steps • The RCU will discuss any Cross-Border requirements with firms individually (ie with those who have head offices elsewhere within the EU) • Firms can begin to prepare for (or certainly start to think about) the 2018 implementation of the information templates • The RCU will now begin to work closely with firms on their templates with a proposed draft submission on 14 th September 2018 – 1 year following the FSRCC Seminar • 2018 update seminar proposed to take place in Q 4 2018 3 November 2017 10
Questions 3 November 2017 Comments 11
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