The EACB gladly takes the opportunity to comment on EBA’s public consultation on its draft Guidelines amending Guidelines EBA/GL/2022/01 on improving resolvability for institutions and resolution authorities to introduce a new section on resolvability testing.
EACB believes that the EBA (in its role as an authority) should provide all banks with a template for the self-assessment to ensure clear guidance and a level playing field. EACB would also welcome a clarification of the change of competence in the transition from recovery to resolution.
As regards the multiannual testing programme, in our view there is no need for authorities to communicate detailed and rigid programmes to the banks.