The members of the EACB welcome the opportunity to comment on the FSB Guiding Principles on the Internal TLAC for G-SIBs.
We support the aim to design a consistent and credible resolution framework, avoiding ring-fencing of assets that could reveal damaging in case of resolution.
However, we would highlight that this should reflect the specific capital structures and support mechanisms of cooperative banking groups and networks, as adequately done in the TLAC term sheet (para. 6(f) and 8(b)).
In particular, the requirement to maintain internal MREL/TLAC between entities belonging to the same Group and in the same jurisdictions negates the very function of cooperative solidarity mechanism and should be reviewed.