世界银行-关于FinSAC客户国所有银行处置单一框架的提案（英）-2025_58页_4mb

Bank Resolution Practices and Single Framework Proposal for FinSAC Client Countries

Key Advantages of a Unified Resolution Approach

A single resolution framework for all banks simplifies handling bank failures in FinSAC client countries, preserving franchise value and safeguarding financial stability. It replaces prohibitive BRRD-aligned requirements with proportional measures, making resolution more accessible while maintaining creditor protections.

Core Recommendations

• Remove PIA as a General Precondition: Rely on the "no creditor worse off than under liquidation" (NCWOL) safeguard to guide resolution actions, ensuring consistency across all bank sizes.
• Adopt Two-Step Sale of Business (SoB): For cases without buyers, use a stabilization phase followed by a competitive sale to expand acquirer pools and mitigate fire sales.
• Proportional MREL Implementation: Apply MREL requirements based on bank size and resolvability; for small banks potentially liquidated piecemeal, focus on liquidation feasibility over recapitalization.
• Industry Funding with Public Backstop: Maximize industry contributions and calibrate public support (via DIF or a resolution fund) to maintain market discipline and reduce taxpayer burden.
• Enhanced Liquidity and Forward-Looking ELA: Integrate emergency liquidity frameworks with resolution planning for timely crisis response.
• Simplified Resolvability Planning: Tailor resolvability expectations to bank scale, with minimal reporting for small banks that rely on liquidation.

Challenges in Current Regimes

• Stringent BRRD Preconditions: The PIA requirement imposes high costs and inconsistencies; removing it streamlines processes.
• Limited Loss Absorption: FinSAC countries face MREL shortfalls, hindering effective resolutions and necessitating alternative funding.
• Operational Hurdles: Small banking systems struggle with data availability, due diligence, and rapid sales during liquidations or transfers.

Benefits

• Consistency and predictability in resolution, reducing regulatory arbitrage and fostering market confidence.
• Cost efficiency, as tools like SoB saves resources compared to piecemeal liquidation.
• Alignment with national contexts for non-EU-aligned countries, supporting EU accession pathways while adapting to local financial structures.

Context for FinSAC Countries

FinSAC client countries possess small, largely deposit-funded banking systems. Proposals draw on EU experiences (e.g., BRRD, US FDIA) while advocating adjustments for proportionality, given their unique socioeconomic and financial environments.

Denominator: for small SoB banks, liquidation may better serve depositor protection, balancing with resolution for larger institutions.