The Single Resolution Board’s (SRB) consultation on its updated Operational Guidance on Liquidity and Funding in Resolution is far more than a tidy-up exercise. It represents a targeted strengthening of operational expectations across liquidity estimation, measurement and reporting, and collateral mobilisation.
According to Regnology, by merging its separate frameworks into a single text, the SRB is sending a clear message: these are not standalone compliance tasks but interconnected disciplines that together form one operational capability banks must be able to prove under crisis conditions.
Regnology recently discussed building operational capability for the Single Resolution Board’s updated liquidity guidance.
A technical meeting on the guidance, held in June, clarified that the consolidation is designed to cut duplication between EfB 3.1, 3.2 and 3.3, while encouraging banks to reuse existing analyses, data and frameworks wherever possible. For lenders, the message is unambiguous: resolution planning can no longer be treated as a theoretical, tick-box exercise.
Nowhere is this more apparent than in the Liquidity in Resolution Estimate (LRE). The SRB is not merely refreshing the requirement, it is raising the bar on the speed, flexibility and resolution-specific nature of the modelling behind it. The fast-moving scenario has been shortened dramatically, with banks now expected to model entry into resolution within one month of a crisis emerging, down from three months previously. Firms must also weigh up variant resolution strategies rather than focusing solely on the preferred route, while group structures face closer scrutiny, with branches and SPVs no longer automatically classed as Key Liquidity Entities.
On measurement and reporting, the SRB expects updated positions within short notice, defined as a maximum of 24 hours, alongside high-frequency capability that goes beyond a single daily snapshot. This is not continuous real-time reporting, but it does demand intraday information where relevant, supported by data lineage and governance standards aligned with BCBS 239.
Collateral mobilisation rounds out the framework, with the SRB assuming a bank’s most liquid assets may already be encumbered. The emphasis shifts to how quickly assets, beyond just HQLA, can realistically be accessed, factoring in location, legal restrictions and custody arrangements.
The consultation closes on 6 July 2026, with analysis expected in the third quarter and final guidance pencilled in for the fourth quarter of the year. Application from the 2027 resolution planning cycle has been proposed, though a staggered rollout is also under consideration.
Banks preparing for the change should focus on three pillars: a unified data foundation spanning risk, treasury and finance; a resilient modelling and governance framework capable of compressed timelines; and an automated, controlled production workflow that maintains data lineage even when manual steps are unavoidable.
Read the full Regnology post here.
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