Question
The general remarks for both templates M05 and M06 state the following: Liabilities excluded from bail-in; these liabilities shall be included to the extent that they rank pari passu with or junior to any instrument included in the amount of eligible liabilities for the purposes of internal MREL (M05)/ MREL (M06). Does this mean that other liabilities excluded from bail-in, i.e. those ranking senior to eligible liabilities will not be included in any of the columns of templates M05 and M06?
Background on the question
Different interpretation of issue by credit institution eligible for MREL reporting/customer and consultancy firm/solution provider
Answer
This question has been rejected because it is considered that EBA guidance or clarification is not needed with regard to the issue that it raises, as it is considered that the existing regulatory framework, namely Article 3 of Regulation (EU) 2016/1450 - RTS specifying criteria for MREL (minimum requirements for liabilities eligible for bail-in) and templates M05 and M06 is sufficiently clear and unambiguous.The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts.For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”