The distinguishing characteristic of bail-in, as a resolution tool, is that it applies losses upfront based upon a valuation rather than at the end of a liquidation of assets. As such, it prospectively avoids an unnecessary destruction of value. For those groups that issue debt from the holding company and downstream the proceeds to operating subsidiaries, it should be possible to bail in debt at the holding company and recapitalise distressed parts of the group. Where necessary, those distressed subsidiaries could be recapitalised by bailing-in – ie writing down and/or converting into equity – intergroup debt owed to the parent. The host authorities of those operating companies should in principle be prepared to go along with that kind of operation provided that the home country engenders the necessary trust and takes account of the need to maintain stability around the world not just in its immediate neighbourhood. Deposit insurance schemes and bail-in: multiple point of entry resolution We should not, however, assume a monolithic approach to resolution. It is not a case of one size fits all. What I have described could work for banking groups that issue plenty of debt out of a top company. It would not work so easily for groups operating commercial banks around the world that are funded to a very large extent from insured deposits. In a hypothetical extreme case, if they haven’t issued bonds, then there would be no bond holders to bail in.
More relevant to today’s conference, following the FSB’s recent Plenary meeting in Tokyo we announced that in the next few weeks we will issue a consultative paper on resolution planning and, in particular, on resolution strategies. The paper, drawn up by a subcommittee led by Christine Cumming of the New York Federal Reserve Bank, will cover three areas. The first is Recovery Triggers and Stress Scenarios used in recovery planning. Firms need to ensure that triggers are not linked mechanically to metrics that lag behind their true financial condition – a problem with some previous earlyintervention frameworks. Recovery actions must start sufficiently early. But care must be taken to avoid markets overacting to the fact of such actions being taken. That is not easy. Second, the consultative paper will outline a possible framework for national authorities to use when identifying the critical functions and support services of firms that need to be sustained in distressed conditions. What matters here is focusing on those services that are vital to the economy. The third, and most important, area of consultation is about the development of Resolution Strategies and Operational Resolution Plans. This guidance aims to capture the main issues that authorities should address.