Considering the high granularity of these draft transferability guidelines, the EACB is of the opinion that they may be more appropriate to banks that have transfer tools as their preferred resolution strategy (PRS) and/or when the transfer perimeter includes critical functions. Accordingly, we consider that the requirements outlined in these draft transferability guidelines should be proportionate to the importance of the tool in the resolution strategy of the bank.
The EACB members welcome the fact that the EBA encourages Resolution Authorities (RAs) to leverage on the recovery information available in recovery plans. Additionally, we encourage the EBA to explicitly stress that the level of implementation of these transferability guidelines should be left to the discretion of RAs, especially when transfer tools are not the PRS.