The Association for Financial Markets in Europe (AFME) welcomes the Commission’s proposals to amend the Capital Requirements Regulation (CRR), Capital Requirements Directive (CRD), Bank Recovery and Resolution Directive (BRRD) and Single Resolution Mechanism Regulation (SRMR). This paper sets out our initial views on the resolution aspects of the proposals including the implementation of Total Loss-Absorbing Capacity (TLAC), as set out in the FSB TLAC Principles and Term Sheet (TLAC Standard), amendments to the Minimum Requirement for own funds and Eligible Liabilities (MREL), the proposal to amend the creditor hierarchy and other recovery and resolution issues.

AFME has been very supportive of the development of an effective recovery and resolution framework in Europe and closely involved in the implementation of the BRRD, development of TLAC and related issues.