The EACB welcomes the opportunity to comment on the SRB Operational Guidance for banks on liquidity and funding resolution. We appreciate the effort to consolidate three Operational Guidance products into a single document. We also emphasise the work done to ensure clarity in the expectations laid down by adjusting wording in areas previously subject to interpretation and the clear reference to the principle of proportionality. In the spirit of strong collaboration between industry and institutions, and to ensure the predictability and stability of resolution policies and arrangements, we highlight remaining concerns in certain areas of the current draft Guidance, such as:
- Necessity of proportionality for simple funding profiles
- Elimination of the slow-moving scenario
- Clarify the FOLTF trajectory assumptions
- Clarification on alternative recovery options beyond the recovery plan
- Phased implementation for the intraday data requirements
- Reduce the redundancy of the qualitative not e on the methodological approach for liquidity scenarios
- Establish a specification of collateral requirements for the purpose of this guidance