The Clearing House (TCH), jointly with the IIF and GFMA, commented on two (here and here) consultations issued by the Financial Stability Board at the end of last year. These two consultations – one on resolution funding strategies and the other on the mechanics of bail-in execution – represent the final build-out of the FSB’s multi-year effort to develop a common set of principles governing the resolution of global systemically important banks, or G-SIBs. Both letters are generally supportive of the principles outlined in the consultations, though TCH recommended certain refinements. Regarding resolution funding strategies and plans, TCH recommended that the FSB principles specifically take into account likely actions under a G-SIB’s recovery plan, and that home resolution authorities publicly provide a general, non-firm specific overview of their resolution funding plans and preferred resolution strategies once they are fully developed. Regarding bail-in execution, TCH generally recommended that authorities provide as much ex ante disclosure and transparency as possible of the bail-in mechanics to reduce market uncertainty.
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