M 02.00, r0490 - SNP issued by EU small banks only

EBA Q&A 2021_6294 · Rejected question

Question

Should we limit our reporting to SNP issued by EU small banks only?

Background on the question

In template M 02.00 (TLAC1), row 0490, it is expected to fill the subordinated debts issued by banks that are not GISB, nor EU D-SIBs. For EU small banks we can identify the rank Senior Non Preferred. For non EU non G SIBs banks, the eligibility to a TLAC/MREL-like ratio will be obtained by a structural or contractual subordination. Nevertheless we are not aware of the countries that have implemented a sort of TLAC/MREL for their medium/small banks.

Answer

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