The EACB welcomes the opportunity to comment on the SRB Operational Guidance on banks’ communication. We understand the importance of defining a proper strategy that can address different circumstances, also in light of the uncertainties observed during the market turbulence in 2023, and their outcome.
While we welcome the SRB’s efforts to enhance the effectiveness and consistency of resolution communication, several aspects of the draft Guidance raise concerns regarding proportionality, clarity, and alignment with the existing EU regulatory framework. In particular, the Guidance appears in certain respects to extend beyond established Level 2 expectations, while also underestimating the role of SRB in fostering clear and effective communication during a resolution case. Taken together, these issues may create unnecessary operational burdens for banks, generate uncertainty about supervisory expectations, and risk diverting resources from genuinely critical resolution-preparedness objectives.
In addition, the Guidance currently lacks clarity regarding the sequencing and content of communication steps, and proportionality in the division of responsibilities between the central public role of SRB, national authorities, and banks. Furthermore, instead of focusing excessively on predetermined timelines, it would be more effective for both, banks and the SRB, to prioritise capability over chronology.