In addition, Estonia and the Netherlands have already adopted systemic risk buffers to counter those risks emerging from groups of banks with similar business models. These three capital buffers address risks linked to the structural features of the banking system. They raise resilience and are applied in a static way.
Countercyclical capital buffers and dynamic loan provisioning, instead, can address cyclical features by increasing capital requirements when systemic risks build up. 7 Until now, no SSM country has adopted positive countercyclical capital buffers given the prevailing subdued position in the credit cycle.