The European Savings and Retail Banking Group (ESBG) submitted its response to the consultation launched by the Single Resolution Board (SRB) in March 2024 on the Minimum Bail-in Data Template (MBDT) which aims to gather feedback on the integrated approach for implementing bail-in data reporting standards across banks under the SRB remit. Once adopted, the MBDT will replace existing instructions and serve as the standard for reporting data relevant to bail-in operationalization during crises or dry-run exercises.

MBDT should have been carried out earlier.

ESBG expresses its support for the new minimum bail-in data template, while emphasizing that this development should have occurred earlier alongside the initial Bail-in Data Set release. Having precise instructions from the start would have allowed institutions to adapt their systems efficiently, avoiding interpretations and system developments based on undefined answers from Internal Resolution Teams (IRTs). Consequently, implementing the new template will require adjustments, as it deviates from some national resolution authorities’ requirements. ESBG requests clarification from the SRB regarding the impact of using the MBDT as the sole reporting basis on different standards’ interaction.

How ESBG suggests enhancing data point model and format?

ESBG highlights that presenting accrued interest separately from the principal liability will increase reporting complexity and slow performance. To address this, a proposal suggests using additional columns for interest amounts and their ranking to avoid splitting records and data fragmentation. This approach maintains the meaningfulness and consistency of transaction records, ensuring the amount eligible for bail-in remains verifiable. ESBG also raises concerns regarding the granularity of records, including repurchase agreements valued on netting in the template. Furthermore, whenever granular information on deposits is required to support the resolution action’s processes, ESBG believes that if both A and B submissions are necessary, the tight 24-hour deadline poses challenges, and perhaps working on solution B could be considered. Grouping liabilities of similar characteristics is seen as beneficial for reducing file generation time and unnecessary rows.

Process: ESBG calls for sufficient time between publication and implementation.

A period of 12 months between the final publication and implementation is tight, especially when you consider that new liability types will be added with B01, and the provision process may have to be significantly adapted. Moreover, a sufficient lead time must be planned for the commissioning of the relevant service providers, as well as for implementation and testing by the institutions concerned