Response to the request for comments on the FSB consultative document on the evaluation of the effects of too-big-to-fail (TBTF) reforms

We think that the FSB should establish a comprehensive monitoring framework to measure IGGs across major banking markets. In addition, the FSB should analyze the loop-holes in the European bail-in regime and make specific policy recommendations on how to close them. This specifically refers to “precautionary recapitalizations” that have been used by certain EU member states to avoid bank resolutions.