The Bank Recovery and Resolution Directive (BRRD), a core piece
of post-crisis regulation aimed at ending 'too big to
fail', is being implemented across the EU. As part of the
journey towards full and consistent implementation, the European
Banking Authority (EBA) recently published a comparative analysis of the recovery plans of
27 (unnamed) European cross-border banking groups which
collectively account for around half of the banking assets in the
EU.
The report focuses on how the banks have dealt with
"critical functions" and "core business lines"
in recovery plans, with an emphasis on the former. The
general message is that the EBA would like to see firms demonstrate
a deeper understanding of their critical functions, and provide
more analysis of how they fit into the recovery plan as a whole.
The EBA recognises that the concepts are relatively new, making the
analysis challenging, but while it commented on the good progress
being made with recovery planning in
