Application of the Key Attributes of Effective Resolution Regimes for Financial Institutions to State-Owned Banks

This paper offers guidance to policy makers and resolution authorities regarding the application of Key Attributes (KA) to State Owned Banks. It deals with banks that have passed the point of non-viability (PONV) but also discusses early-stage requirements and procedures prescribed by the KAs that aim to improve resolution if it should become necessary. The KAs were developed to apply to “any financial institution that could be systemically significant or critical,” which includes SOBs. The key potential issues that could affect the implementation of the KAs for the resolution of SOBs are identified and, where possible, alternatives to address them, or to mitigate their impact, are provided. Among them, the removal of barriers that prevent the resolution authority (RA) from placing a failing SOB under resolution features preeminently. Authorities should also address issues related to resolution funding, which tend to take a prominent role in the case of SOBs, given the fiscal implications. The paper is also useful for bank resolution practitioners challenged with the implementation of resolution regimes for SOBs. The paper does not intend to be conclusive but rather to frame the discussion on the application of the KAs to SOBs, with the objective of feeding the necessary discussions of these issues by the international community.