Before jumping into the harmonisation of liquidation regimes, it must be acknowledged that this is not a silver bullet. Indeed, the considerable social and economic impact ensuing from the failure of a bank with systemic relevance at local level would remain.
It seems clear that the BRRD creates a comparative advantage for larger banks.16 As recently stressed by Fernando Restoy, and experienced first-hand by Professor Panicos Demetriades during his tenure as Governor of the Central Bank of Cyprus, there is no clear room for a ‘middle class’ of institutions whose failure, and eventual liquidation, could be considered systemic but whose business model may be incompatible with the satisfaction of MREL requirements.