The European Commission Implementing Regulation (EU) 2018/1624 of 23 October 2018 (“the CIR”) establishes a minimum harmonised standard of procedures, templates and instructions for the provision of information for the purposes of resolution plans for credit institutions and investment firms.
Template Z.09.00 FMI should be filled with information on the use of Financial Market Infrastructure (FMI) providers. The content of that template represents the minimum information needs at European Union level and the SRB requires more data to develop the relevant chapters of resolution plans. As the inability to ensure continuity of access to FMIs during bank resolution may be considered as one of the potential impediments to resolvability, it is important for the SRB to obtain additional data on FMI access and to further understand the conditions for maintaining access to FMIs and the potential impact of discontinued access.
The SRB and the National Resolution Authorities (NRAs) of the Banking Union Member States have developed a more complete template for the collection of such information (the FMI report).
The FMI report
The FMI report is meant to provide a detailed overview of banks’ participation in FMIs. In addition to the information requested under the Implementing Regulation, the SRB requests banks to report:
- Qualitative information on the system and on the use of the system by the reporting institution: currency used by the entity in the FMI, ancillary services received from the FMI, service providers needed to access the FMI etc.;
- Quantitative data to measure the extent to which the reporting institution uses the FMI and the exposure of the reporting entity and of its clients (if any) vis-à-vis the FMI, or vice-versa. In addition, information is requested on currently available credit lines and on peak (intraday) liquidity requirements, to support the assessment of potential increased liquidity requirements under stress; and
- Qualitative data necessary to facilitate resolution, e.g. contacts within the FMI.
The template does not aim to provide an in-depth understanding of critical FMIs. Also, the template does not capture all the details that may be needed to maintain continued access to critical FMI service providers (necessary for critical functions or core business lines).
Key changes in 2019
The template and the guidance note accompanying the template have been modified as follows for the 2019 reporting cycle:
- Definitions were aligned with the CIR. Some definitions have been further clarified following the 2018 Q&A exercise.
- Some purely qualitative fields (e.g. on membership requirements, substitutability or consequences of resolution) were removed from the template, with the understanding that banks would be asked to provide such information through more appropriate means.
Please pay attention to the following points:
- Institutions do not need to complete Template Z.09.00 FMI required to be reported under Commission Implementing Regulation (EU) 2018/1624. That template (included as a linked worksheet in the SRB spreadsheet) will be automatically populated when banks fill the SRB FMI template. Institutions should nevertheless verify that the information thereby included in Z.09.00 FMI is indeed correct and in line with the reporting requirements outlined in the CIR.
- Scope: Z.09.00 FMI only includes FMI service providers which are necessary for the provision of critical functions. The scope of the SRB FMI template is broader. Please include all Relevant Legal Entities, as well as any other entities communicated by resolution authorities. Please also include all FMI (direct and indirect) participations and memberships, as well as use of trading venues and intermediaries.
- Definitions: Elements that are also requested in Z.09.00 FMI shall be considered to fall under the same definition as in the CIR. In case of any remaining discrepancies the text of the CIR should prevail.
The deadline for submission of the reports by banks to NRAs is 30 April 2019.
Frequently Asked Questions
Questions relating to the report can be submitted to Internal Resolution Teams (IRTs). A preliminary FAQ is included in the guidance note.
 IRTs are responsible for preparing resolution plans for banks under the SRB’s remit. They consist of experts from the SRB as well as relevant NRAs.