MREL is determined only after deciding “how that bank would be resolved”
MREL (Minimum Requirement for Own Funds and Eligible Liabilities) is the minimum level of “own funds plus eligible liabilities” that a bank must build up in normal times so that, when it enters resolution, loss absorption and recapitalisation can be completed on the shareholder and creditor side rather than through taxpayer support. In both the UK and the EU, the purpose of the regime is the same: to ensure that a bank can be resolved without interrupting critical functions. However, it misses the essence to understand MREL simply as a “thicker capital requirement.” Ordinary capital regulation is a going concern framework, aimed at prudential soundness on the assumption of continued operation in normal times. MREL is a gone concern framework, aimed at ensuring that there is a source of funds that can actually be bailed in in resolution. That is why not only CET1, AT1, and Tier 2 but also certain senior debt instruments that meet specified conditions can count toward it. But not every...