Minimum Requirement for own funds and Eligible Liabilities (MREL)
The BRRD, which has been transposed in all participating Member States in the Banking Union, requires banks to meet MREL targets so as to be able to absorb losses and restore their capital position, allowing them to continuously perform their critical economic functions during and after a crisis. MREL represents one of the key tools in enhancing banks’ resolvability.
In 2017, the SRB developed its MREL policy and adopted its first binding decisions for major banking groups.
Given the need to address the specificities of the most complex groups in more detail, the SRB split the 2018 resolution planning cycle into two waves. The first part started in January 2018 to allow banks that did not have binding targets (such as those without a presence outside the Banking Union) to be addressed first based on a MREL policy largely following the 2017 approach. This was published on 20 November 2018.
For the second wave of resolution plans, covering the most complex banks, MREL setting was based on an enhanced MREL policy published on 16 January 2019. This second part of the 2018 MREL policy introduces a series of new features to strengthen the MREL approach and banks’ resolvability within the Banking Union.
In June 2019 the SRB published an update to its 2018 MREL policy in light of the publication of the Banking Package (CRR2/CRD5/BRRD2/SRMR2) in the Official Journal of the EU on 7 June 2019. This was followed by an overall updated MREL Policy under the Banking Package (BRRD2/SRMR2) published on 20 May 2020, which covers:
- MREL requirements for Global Systemically Important institutions (G SIIs);
- Changes to the calibration of MREL, including introducing MREL based on the leverage ratio;
- Changes to the quality of MREL (subordination);
- Dedicated rules for certain business models, such as cooperatives, and for resolution strategies, such as multiple point of entry (MPE);
- Provisions on internal MREL;
- Clarifications on third-country issuances; and
- How these changes will be phased in.
MREL decisions implementing the new framework will be taken based on the MREL Policy under the Banking Package in the 2020 resolution planning cycle. The decisions will be communicated to banks in early 2021. These decisions will replace those issued under the previous legal framework. Each new decision will set out two binding MREL targets, including those for subordination: the binding intermediate target to be met by 1 January 2022 and the fully calibrated MREL (final target) to be met by 1 January 2024.
- 2018 SRB Policy for the first wave of resolution plans
- 2018 SRB Policy for the second wave of resolution plans
- CRR Addendum to the 2018 SRB Policy for the second wave of resolution plans
- 7th Industry Dialogue Presentation on MREL