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Bank capital
This section consolidates ICMA responses to consultations concerning various forms of bank capital, including the characteristics of additional tier 1 capital, buffer contingent capital securities and bail-in.

30 August 2016

Click here to see the ICMA response to the EBA Interim Report on MREL.

16 May 2016

Click here to see the Joint BBA/ICMA response to the UK PRA’s consultation on the contractual recognition of bail-in.

31 July 2015

Click here to see the ICMA Bail-In Working Group's discussion letter to the ECB, the purpose of which is to set out views on the operation of the bail-in mechanism.

27 January 2015

Click here to see the ICMA response to the UK FCA’s consultation on restrictions on the retail distribution of regulatory capital instruments.

12 September 2014

Click here to see the ICMA Bail-in Working Group’s response to the questions enumerated in the Financial Policy Committee’s Review of the Leverage Ratio.

3 July 2012

Click here to see ICMA's response to the questions enumerated in the European Banking Authority (EBA) Consultation Paper on Draft Regulatory Technical Standards on Own Funds.

20 April 2012

Click here to see ICMA's letter in response to the questions in the European Commission’s "Discussion paper on the debt write-down tool – bail-in"

31 January 2012

Click here to see the response from the European Banking Authority (EBA) to the ICMA letter and survey on EBA's term sheet for Buffer Convertible Capital Securities (BCCS).

17 January 2012

On 8 December 2011, the European Banking Authority (EBA) published a formal recommendation on the creation of temporary capital buffers, the objective of which is to create an exceptional and temporary capital buffer to address current market concerns over sovereign risk (the “Stress Capital Requirement”), and which may include very strong newly issued buffer convertible capital securities (“BCCS”) if consistent with the EBA “Buffer Convertible Capital Securities Common Term Sheet”.

One of the key advantages of issuing BCCS to meet the temporary Stress Capital Requirement is that it gives issuers access to the fixed income investor base to raise EBA Core Tier 1 eligible capital, and therefore the possibility of using BCCS to tap supplementary investor sources for Core Tier 1 capital is welcomed.

However, in order for the BCCS to be fit for purpose, as well as achieving the regulatory objectives, the host instrument needs to be sufficiently attractive and marketable.

With marketability being the main influential factor, we conducted a survey on the matter among major market participants. More precisely, we asked a series of questions comparing the market impact of BCCS with a Tier 2 host with otherwise identical BCCS with an Additional Tier 1-style host.

Click the links below to see:
See also, Katie Kelly's article "EBA Bank Recapitalisation Plan" in the ICMA Quarterly Report First Quarter 2012.

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