UK Finance has responded to HMT's consultation on implementing The Bank Recovery and Resolution Directive II  before the end of the Transition period.

We supported the approach of maintaining alignment with the existing well thought out UK MREL framework, but suggested that the planned step up in MREL requirements should be delayed until the beginning of 2024 in line with the EU plans.

We, however, raised issues about the status of bail-inable instruments that will lose their MREL recognition as a result of the changes, the impact of over-riding UK's gold plated approach on resolution stay powers and suggested that moratorium powers should not be applied to retail or operational deposits.