Proportionality of MREL for Transfer Strategies in the Context of the CMDI. Initial Considerations

379 Even in light of the proposal to strengthen the common framework for bank crisis management and national deposit guarantee schemes (CMDI), MREL (minimum requirement for own funds and eligible liabilities) in the context of bank crisis resolution continues to be a key tool. However, it seems clear that the rules determining MREL calibration may require revision if transfer strategies, which seem more suitable for resolving medium and small banks, are to play a greater role. The CMDI Proposal does not seem to fully develop such a revision. This raises concerns that we may miss a good opportunity to enable market-based resolution tools that are less burdensome for taxpayers.