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2022 Investment Plan

The 2022 Investment Plan is one of the strategic tasks that is covered in-house by the SRB. It is an adopted outsourcing model with more than one investment manager underpinned by a single custodian. Two external investment managers will monitor the implementation of the 2022 investment plan. The SRB reviews the investment strategy and prepare the annual investment plan for the following year.


Advisory Technical Committee (ATC)

The Advisory Technical Committee (ATC) provides advice and assistance on issues relevant to the work of the European Systemic Risk Board (ESRB). The ATC consists of:

  • a representative of each national central bank of the Member States and a representative of the European Central Bank (ECB)
  • one representative per Member State of the competent national supervisory authorities (the respective representatives rotate depending on the item discussed, unless the national supervisory authorities of a particular Member State have agreed on a common representative)
  • representatives of: EBA, EIOPA, ESMA, EC (2), ECB, SRB, EFC, ASC, national bank of Iceland, national bank of Norway, Ministery of Finance of Liechtenstein and one supervisory authority of EFTA States

Annual Resolvability Assessment

The SRB is responsible for producing a resolution plan for each of the banks under its remit. As part of this, the Internal Resolution Teams (IRTs) must assess how resolvable each bank is. This is called the Resolvability Assessment, practiced on a yearly basis during the resolution planning cycle (RPC).

IRTs base their resolvability assessment, among others, on a target/performance comparison of banks’ multi-annual resolvability work programme and annual resolvability progress reports with the EfB and the annual SRB priority letter.

For the Resolvability Assessment, benchmarks such as the legal framework, the Expectations for Banks and the policy for setting Minimum Requirements for own Funds and Eligible Liabilities (MREL) are used. This ensures that banks maintain a minimum amount of equity and debt to support an effective resolution

Annual Resolvability Assessment Process (RAP)

A Resolvability Assessment Process (RAP) is conducted annually in respect of all G-SIBs to promote adequate and consistent reporting on resolvability at a global level and to determine what should be done to address material recurring issues with respect to resolvability.

The assessment is conducted in Crisis Management Groups (CMGs), set up by the SRB. They execute the assessments for the global systemically important banks (G-SIBs) under the SRB’s remit.

Annual resolvability progress reports

The annual reports provided by the banks containing at the least a statement of their compliance with the EfB and the annual SRB priority letter.

Annual SRB priority letter

Annual letter sent to each bank under the SRB’s remit. Each letter sets specific priorities for each bank for the coming year. Underpinning these priorities, the SRB has developed guidance for banks and the SRB internal resolution teams (IRTs), providing clear and solid ground for banks to achieve resolvability in line with the SRB Expectations for Banks.

Annual Work Programme

The Annual Work Programme of the SRB sets out the agency’s objectives and priorities, as part of the SRB Multi-Annual Programme (MAP).

Appeal Panel

The SRB Appeals Panel serves as an independent panel. It decides on appeals against a decision of the Board, submitted by any natural or legal person, including resolution authorities.

The Appeal Panel acts as an independent body, which, although supported by the SRB, is fully independent. It was established under Regulation (EU) No 806/2014.

The Appeal Panel is composed of five individuals of high repute, from across the Banking Union, and with a proven record of relevant knowledge and professional experience, who will act independently and in the public interest.

Asset Separation Tool

As defined in Art. 3 (32) SRMR.


An arrangement is any agreement, contract, policy, procedure, guideline or practice governing the provision of a service


Back-to-back (booking) Transaction

A pair of legally separate transactions, but with the same terms of trade and involving three parties. One party is the intermediary, as the buyer in one transaction and the seller in the second transaction. This allows institutions to book the transaction in a different place to the original business.


As defined in Art. 3 (33) SRMR.


Bail-outs occur when outside investors, such as a government, rescue a borrower by injecting money to help make debt payments. In the past, this helped save the companies from bankruptcy, with taxpayers assuming the risks associated with their inability to repay the loans.

Banking Union

The European Banking Union (EBU) was established at the Euro Area Summit of 29 June 2012, as a reaction to the financial crisis in 2008. Its rationale is to establish an ‘Europeanised bank safety net’. The Banking Union consists of the Single Resolution Mechanism (SRM), the Single Supervisory Mechanism (SSM) and the Single Deposit Guarantee Scheme.

Today, the Banking Union consists of two pillars: a Single Supervisory Mechanism (SSM) and a Single Resolution Mechanism (SRM). Both are contributing to financial stability and a level-playing field for banks in the Eurozone.

Basel III reforms

Basel III is an international regulatory accord that introduced a set of reforms designed to mitigate risk within the international banking sector by requiring banks to maintain certain leverage ratios and keep certain levels of reserve capital on hand. Begun in 2009, it is still being implemented as of 2022.

It is an international regulatory accord that introduced a set of reforms designed to improve the regulation, supervision, and risk management of the banking sector.

Bank recovery plans

According to Articles 5 and 6 of the BRRD , Union parent undertakings and institutions (which are not part of a group subject to consolidated supervision pursuant to Articles 111 and 112 of Directive 2013/36/EU) should draw up and maintain recovery plans providing for measures to be taken to restore their financial position following a significant deterioration.

The content of recovery plans is regulated in the Commission Delegated (EU) 2016/1075, endorsing the EBA final draft Regulatory Technical Standards (RTS) on the content of recovery plans. Along with strategic information on the institutions’ structure and governance, plans should include a minimum set of recovery plan indicators and a range of scenarios to test recovery options. Recovery plan indicators aim at identifying the points at which the escalation process in the bank should be activated and where needed, any appropriate actions referred to in the recovery options taken. The EBA has recently proposed a revised list of recovery plan indicators (EBA GL on recovery plan indicators)  which now includes a new MREL indicator.

Bank Recovery and Resolution Directive (Directive 2014/59/EU)

In response to the 2008 financial crisis, the EU established an orderly cross-border resolution mechanism via the Bank Recovery and Resolution Directive (BRRD – 2014/59/EU), which provides resolution authorities with comprehensive powers and resolution tools to intervene when a bank meets the conditions for resolution. Resolution authorities have to prepare resolution plans detailing how a bank will be resolved, in a way that achieves the resolution objectives, while ensuring taxpayers avoid carrying the burden, as was the case in the 2008 crisis.

Bank Recovery and Resolution Directive and Single Resolution Mechanism Regulation (BRRD/SRMR) framework

The BRRD/SRMR framework builds the EU legislative framework on bank resolution. The Single Resolution Mechanism was put in place in addition to the Bank Recovery and Resolution Directive in December 2021. The main reason for this was to add to the mere network of national resolution authorities and resolution funds to resolve banks, which the BRRD is. The Single Resolution Mechanism enables bank supervision and resolution to be exercised by the same level of authority. With an additional strong central decision-making body and a Single Bank Resolution Fund, the SRMR in addition to the BRRD ensures that resolution decisions across participating Member States are taken effectively and quickly, benefitting Member States, taxpayers, banks, and financial and economic stability in the entire EU.

Bridge Institution

As defined in Art. 3 (31) SRMR.

BRP analysis report

With the draft of a Business Reorganisational Plan, banks show to be capable to ensure their financial soundness and long-term viability. The analysis of such capabilities are demonstrated by banks in a so-called BRP report.

Banks are required to establish proper governance arrangements and provide an analysis of the main components of the BRP.

Business Continuity Plan (of the SRB)

Reflects the organisational evolution of the SRB, in particular the Business Impact Analysis and Business Process Map overview documents.

Business Lines

A structured set of activities, processes and operations that is developed by the institution for third parties to achieve the organisation’s goals.

Business Impact Analysis (of the SRB)

The Business Impact Analysis, analyses the impact of a major disruption over time based on different impact categories in order to identify the most time critical business processes for the SRB.

Business Process Map (of the SRB)

Business process mapping, determines how outputs/services should be delivered, what resources (human, financial, technological) are needed, what are the important points to monitor and how processes can be improved. It is also useful to keep a repository for the future and establish an SRB taxonomy.

Business Reorganisation Plan (BRP)

The draft of the Business Reorganisation Plan is intrinsically linked to the use of the bail-in tool. With such a plan, banks show to be capable to ensure their financial soundness and long-term viability. The analysis of such capabilities are demonstrated by banks in a so-called BRP report.

Banks have the capability to draft BRPs that would have to be delivered within 1 month following bail-in execution (as required by the legislation and as detailed by principle 7.3 of the Expectations for Banks (EfB)).


Capital Requirements Directive (CRD)

Directive 2013/36/EU.

Capital Markets Union (CMU)

The capital markets union (CMU) is a plan to create a single market for capital. The aim is to get money – investments and savings – flowing across the EU so that it can benefit consumers, investors and companies, regardless of where they are located.

Central Counterparty (CCP)

An entity that places itself, in one or more markets, between the counterparties to the contracts traded, becoming the buyer to every seller and the seller to every buyer, and thereby guaranteeing the performance of open contracts.

Central Counterparty Clearing (CCPs)

A central counterparty clearing party (CCP) is an entity that helps facilitate efficiency, safety and stability of trading in various European derivatives and financial markets. CCP’s are usually operated by the major banks in each country. CCPs perform the functions of clearing and settlement. A CCP guards against the default of one or both parties in a trading deal: the buyer and seller

Central Securities Depository (CSD) An entity that 1) enables securities transactions to be processed and settled by book entry; 2) provides custodial services (e.g. the administration of corporate actions and redemptions); and 3) plays an active role in ensuring the integrity of securities issues.


The process of transmitting, reconciling and, in some cases, confirming transfer orders prior to settlement, potentially including the netting of orders and the establishment of final positions for settlement. Sometimes this term is also used (imprecisely) to cover settlement. For the clearing of futures and options, this term also refers to the daily balancing of profits and losses and the daily calculation of collateral requirements.

Collateral in Resolution

Collateral is an item of value that a lender can claim from a borrower if they fail to repay a loan according to the agreed terms. One common example is the mortgage. When you take out a mortage, the bank will ask you to provide your home as collateral.

Collateral in Resolution refers to the amount of assets of a bank that could be mobilised as collateral in and after resolution.

Collateral policy

The SRB has developed a collateral policy to provide liquidity support when the Common Backstop to the Single Resolution Fund (SRF) is used, which should be considered for SRF liquidity support in general. Under this collateral policy, the SRF will provide liquidity on a fully collateralised basis when available and practical. In principle, almost all asset classes are eligible under the SRF collateral framework, and an independent valuation will be performed and haircuts applied according to the internal risk framework developed by the SRB.

College Banks

Banks for which a college has been established, in accordance with Art. 88 BRRD.

Combined Buffer Requirement (CBR)

Total CET1 capital required to meet the requirements for the capital conservation buffer.

Common Backstop

The Common Backstop is to be used as financial back-up to the Single Resolution Fund (SRF). The Common Backstop is intended to ensure that the SRB would have sufficient firepower to address even a severe systemic crisis, should the SRF have insufficient funds. The ESM was agreed as the provider of the Common Backstop.

Comply-or-explain Basis

Comply-or-explain is a regulatory approach used in the field of corporate governance and financial supervision. Rather than setting out binding laws, the SRB sets out guidelines, which SRB banks may either comply with, or if they do not comply, explain publicly why they do not.

The comply-or-explain basis has for example been amended in the Resolution Planning Manual and LSIs Guidelines and is applied when Internal Resolution Teams (IRTs) or LSIs deviate from the established policies. This ensures compliance with the rulebook, high standards and consistency in resolution planning for SRB banks.

Core Business Lines

Business lines and associated services that represent material sources of revenue, profit or franchise value for an institution, or for a group of which an institution is a part.

Credit default swaps (CDS)

Credit default swap (CDS) refers to a financial derivative that allows an investor to swap or offset their credit risk with that of another investor. To swap the risk of default, the lender buys a CDS from another investor who agrees to reimburse the lender in the case the borrower defaults.

Crisis Management and Deposit Insurance (CMDI)

The EU bank crisis management and deposit insurance framework dictates the rules for handling bank failures while protecting depositors. It consists of three EU legislative texts acting together with relevant national legislation: the Bank Recovery and Resolution Directive (BRRD – Directive 2014/59/EU), the Single Resolution Mechanism Regulation (SRMR – Regulation (EU) 806/2014), and the Deposit Guarantee Schemes Directive (DGSD – Directive 2014/49/EU).

Crisis Management Groups (CMGs)

Crisis Management Groups (CMGs) are set up by the SRB. They execute the annual Resolvability Assessment Process (RAP) for the global systemically important banks (G-SIBs) in the SRB’s remit.

CMGs are composed of the resolution authorities, supervisory authorities, central banks, finance ministries and public authorities responsible for DGSs of the countries where entities of the G-SIBs are located that are considered material to potential resolution of the G-SIBs. The authorities involved in CMGs sign institution specific Cooperation Agreements in which they specify the information exchange between them and the processes for information sharing with non-CMG authorities.

Crisis Management Teams (CMTs)

CMTs are bank-specific crisis teams. The SRB’s Resolution Tactical Team (RTT) provides targeted guidance and support to these teams, involving SRB and NRA staff, in order to promote consistent approaches and best practices in terms of crisis management.

Critical Financial Market Infrastructure (FMI services)

Payment, clearing, settlement or custody services, provided by an FMI or by an intermediary, which are necessary for the continuity of one or several critical functions

Critical Functions

Activities, services or operations, the discontinuance of which is likely to lead in one or more Member States to the disruption of services that are essential to the real economy or to disrupt financial stability due to the size, market share, external and internal interconnectedness, complexity or cross-border activities of an institution or group, with particular regard to the substitutability of those activities, services or operations.

Critical Functions Report

An SRB reporting requirement for banks to provide information on their self-assessment of critical functions:

Critical Services

Services, which are necessary for one or more critical functions, that are performed for group business units or entities and whose discontinuity would seriously impede or prevent the performance of those critical functions.

Cross-border group crisis

The fragmentation of banks across national borders results in structures in which banks have multiple entities located in different legal systems. Cross-border group crisis refers to a crisis happening to a bank group that has this type of cross-border structure.



Deep dives are dry-runs by Internal Resolution Team (IRTs) to assess specific topics (i.e. governance, communication, use of the resolution tools, etc.), and dry-runs by NRAs to enhance readiness to implement resolution decisions. Through deep-dives, specific topics and/or processes in crisis are investigated.

In 2022, the SRB will aim in particular at organising dry-run exercises to further test the operationalisation of bail-in, including the enhanced bail-in calculator tool.

Deposit Guarantee Schemes (DGS)

As described in the Deposit Guarantee Schemes Directive (DGSD – 2014/49/EU), Deposit guarantee schemes or ‘DGSs’ are schemes that refer to a) statutory deposit schemes, b) contractual deposit schemes that are officially recognised as deposit schemes, c) institutional protection schemes that are officially recognised as deposit schemes, and d) credit institutions affiliated to these schemes.

Deposit Guarantee Schemes Directive (DGSD)

As established in the Directive 2014/49/EU. The DGSD constitutes an essential instrument for the achievement of the internal market from the point of view of both the freedom of establishment and the freedom to provide financial services in the field of credit institutions, while increasing the stability of the banking system and the protection of depositors.

Digital Operational Resilience Act (DORA)   

The Digital Operational Resilience Act is established by the European Commission and serves to consolidate and upgrade Information and Communications Technology (ICT) risk requirements throughout the financial sector.  DORA aims to ensure that all participants in the financial system have the necessary safeguards in place to relieve cyber-attacks and other risks. The proposed legislation will require firms to ensure that they can withstand all types of ICT-related disruptions and threats.

Dry run

The SRB executes two types of dry-runs:

  • Fully fledged dry runs simulate (parts of) the management process and decision-making in resolution cases. It tests and improves cooperation on resolution-related topics (on a broad range of objectives) as well as decision-making procedures with NRAs and external stakeholders.
  • Technical dry runs investigate specific topics and/or processes in crisis. In 2022, the SRB will aim in particular at organising dry-run exercises to further test the operationalisation of bail-in, including the enhanced bail-in calculator tool.


Describes situations where an employee paid by one legal entity provides services to another entity


Early Warning System for LSIs

This is an early warning model tailored for smaller European banks (Less Significant Institutions, LSIs), to predict distress events. The warning system is set up within the framework of the Bank Recovery and Resolution Directive.


The Economic and Financial Affairs Council (ECOFIN) is the council of ministers responsible for EU policy in three main areas: economic policy, taxation issues and the regulation of financial services.

The ECOFIN is made up of the economic and finance ministers from all European member states. Relevant European Commissioners also participate in meetings.

Essential Services

Services associated with core business lines, whose continuity is necessary for the effective implementation of the resolution strategy and any consequent restructuring.

Essential FMI Services

Payment, clearing, settlement or custody services, provided by an FMI or by an FMI intermediary, which are necessary for the continuity of one or several core business lines (please refer to the definition of “Essential services”).

European Banking Authority (EBA)

The European Banking Authority is an independent EU Authority, which works to ensure effective and consistent prudential regulation and supervision across the European banking sector.

European Deposit Insurance Scheme (EDIS)

The European Deposit Insurance Scheme (EDIS) is the third and final pillar of the Banking Union. July 2022, EDIS is not completed yet. By establishing EDIS, the Banking Union will be completed.

EDIS builds on and collaborates with the system of national Deposit Guarantee Schemes (DGS) regulated by Directive 2014/49/EU. Other than this system, which ensures that all deposits up to €100,000 are protected through national DGS all over the EU, EDIS would apply to deposits below €100,000 of all banks in the Banking Union. When one of these banks is assessed as failing of likely to fail, and a pay-out of deposits or bank transfer is demanded, the national DGS and EDIS will intervene.

With the completion of EDIS, a stronger and more uniform degree of insurance cover would be established in the euro area. The objective of the scheme is to deepen the economic and monetary union.

European Stability Mechanism (ESM)

The European Stability Mechanism is established in 2012 by member states of the euro area. The mission of this intergovernmental organisation is to enable the countries of the euro area to avoid and overcome financial crises and to maintain long-term financial stability and prosperity. It does so through the granting of loans and financial assistance to member states in need.

European Systemic Risk Board (ESRB)

The European Systemic Risk Board (ESRB) was established in 20210 to supervise the financial system of the European Union and prevent and mitigate against systemic risk. The ESRB’s remits covers a wide range of actors, including banks, insurers, asset managers, shadow banks, financial market infrastructures and other financial institutions and markets.

Ex-ante contributions

Ex-ante contributions in the context of the Single Resolution Board refer to those described in the Commission Delegated Regulation (EU) 2015/63). These are ex-ante contributions to resolution financing arrangements.

All banks across the 21 Banking Union countries must pay by law an annual fee to the Single Resolution Fund. These fees are called ex-ante contributions. Ex-ante contributions are paid annually at individual (solo) level by all credit institutions and some investment firms authorised in the Member States participating in the SRM.

The SRB is responsible for the calculation of contributions, defining their height based on the (EU)2015/63 regulation. The regulation specifies the eamount of an institution’s individual contribution to the Single Resolution Fund, depending on its size and risk profile.

Expectations for Banks (EfB)

Expectations for Banks are the actions banks under the SRB’s remit are expected to undertake to ensure an appropriate level of resolvability. EfB is structured along seven dimensions for assessing resolvability:

  • Governance;
  • Loss absorption and recapitalisation capacity;
  • Liquidity and funding in resolution;
  • Operational continuity and access to financial market infrastructure (FMI) services;
  • Information systems and data requirements;
  • Communication; and
  • Seperability and restructuring

‘Extended’ Executive Session

Depending on the tasks, the SRB convenes in different compositions. In case the Executive Session (or: restricted Executive Session) deliberates on a specific bank, the Executive Session is extended (‘extended’ Executive Session) to include the Board Members that represent relevant NRAs. Hence, the composition of the ‘extended’ Executive Session depends on the individual bank in issue. If the ‘extended’ Executive Session is not able to reach a joint agreement by consensus, the Chair and the four further full-time Board Members take a decision by simple majority.


Failing or likely to fail (FOLTF)

Should the authorities declare a bank failing or likely to fail, resolution occurs. A status of a bank as failing or likely to fail means that there is no other supervisory or private sector intervention that can restore the bank entity to viability (for example by applying measures set out in a so-called recovery plan, which all banks are required to draft) within a short timeframe and that normal insolvency proceedings would cause financial instability while having an impact on the public interest.

Financial Continuity

In order to effectively implement the preferred resolution strategy, it must be ensured that arrangements are in place to continue the bank’s critical functions during and after resolution. Financial continuity refers to the section of a resolution plan which describes the liquidity and funding required during and after resolution and how to maintain or regain access to liquidity and funding.

Financial stability of a failing entity is crucial to safeguard the continuation of the bank’s critical functions, regardless of whether they will remain within the bank under resolution or will be transferred to a third party purchaser or to a bridge bank.

Financial Market Infrastructures (FMIs)

FMIs are used for the clearing, settlement, and recording of monetary and other financial transactions. FMIs include payment systems, central securities depositories and central counterparties. Access to FMIs can be vital for the continuity of a bank’s critical functions.

Access to Financial Market Infrastructure services builds one of the seven dimensions of resolvability.

Financial Stability Analysis

The financial stability analysis allows the SRB to conclude on the impact of a potential resolution on financial market functioning and market confidence, FMIs, other financial institutions and the real economy, as required under Commission Delegated Regulation (EU) 2016/1075.

Financial Stability Board (FSB)

The FSB is an international body that oversees and provides recommendations about the global financial system. It promotes international financial stability by coordinating national financial authorities and international standard-setting bodies as they work toward developing strong regulatory, supervisory and other financial sector policies. It facilitates a level playing field by promoting coherent implementation of these policies across sectors and jurisdictions.

FMI Intermediaries

FMI service providers other than FMIs. More often than not, these will be other institutions offering payment, clearing and settlement services, including by way of facilitating indirect access to an FMI.

FMI Report

An SRB reporting requirement for banks to provide information on participation in or membership of FMIs and use of FMI intermediaries for payment, clearing, settlement and custody services:


Green Financing

Green finance is to increase the investments coming from banking, micro-credit, insurance and investment entities in the public, private and not-for-profit sectors that integrate environmental, social and governance (ESG) criteria into their investment decisions. Key objective of this is to encourage the development of a more sustainable economy.

Global Systemically Important Bank (G-SIB)

Global Systemically Important Bank (G-SIB) as defined by the Financial Stability Board, depending on the scale and the degree of influence they hold in global and domestic financial markets.

Group Entities

Each legal entity that is part of a group.


Impact Assessment

Impact assessments examine whether there is a need for EU action and analyse the possible impacts of available solutions. These are carried out during the preparation phase, before the Commission finalises a proposal for a new law. They provide evidence to inform and support the decision-making process.

Impact Analysis

A bank must identify its critical functions in the context of drawing up its recovery plan. To this end, the bank must perform an ‘impact analysis’ and a ‘supply side analysis’. The impact analysis focuses first on the impact of a sudden discontinuation of a function on third parties. Secondly, the impact on financial markets and the real economy with respect to potential contagion effects and general market confidence should be analysed.

Implementing Technical Standards (ITS)

The SRB refers to the ITS as developed by the EBA. These Implementing Technical Standards (ITS) aim at implementing uniform reporting requirements which are necessary to ensure fair conditions of competition between comparable groups of credit institutions and investment firms. Uniform requirements will ultimately make institutions more efficient and result in a greater convergence of supervisory practices.

Indirect Holding

In accordance with Art. 1 (114) CRR. Institution A credit institution or investment firm.

Internal Resolution Team (IRT)

IRTs are responsible for preparing resolution plans for banks under the SRB’s remit. They consist of experts from the SRB as well as relevant NRAs.

International Securities Identification Number (ISIN)

The International Securities Identification Number (ISIN, ISO 6166) is the recognised global standard for unique identification of financial instruments.

Intergovernmental Agreement (IGA)

The SRM constitutes on the Regulation (EU) No 1093/2010 and an Intergovernmental Agreement (IGA)  on the transfer and mutualisation of contributions to the Single Resolution Fund. The agreement allows the SRB to take over full responsibility for bank resolution as planned on 1 January 2016.

Inter-Agency Appeal Proceedings Network (IAAPN)

Created in June 2018, the IAAPN is a sub-network of the Heads of EU Agencies network. Its aim is to promote co-operation and co-ordination between the different EU agencies, to enable the exchange of knowledge and best practice and to prepare common positions where necessary.

Internal Control and Document Management Office (DMO)

The Internal Control Office (ICO) maintains the SRB Internal Control Framework (ICF), which is based on the framework used by the Commission for its own services, by assessing the effectiveness of the internal control systems of the SRB. In addition, the SRB Internal Control team facilitates and coordinates the annual SRB-wide (corporate) risk management process by conducting the risk identification and assessment exercise, establishing and maintaining the Corporate Risk Register and the relevant action plans by centrally monitoring them and reporting their progress to the Board Members as the ultimate risk owners.

The DMOs are responsible for ensuring the SRB documents are managed efficiently and in a consistent way, following internal rules and procedures. They can advise and support the business areas in managing effectively electronic and paper documents, in the view of long term preservation.

Internal Control Framework (ICF)

The SRB Internal Control team maintains an Internal Control Framework (ICF) in order to monitor
the effectiveness, efficiency and economy of the SRB’s activities and its resources, safeguard
its assets and information, prevent and detect irregularities and fraud, provide reliability of
reporting and facilitate the risk management process for its operations and environment. March 2021
year, the SRB Internal Control team implemented the adapted version of a new,
principles-based ICF, which will be based on best international practices and, by analogy, on the
ICF laid down by the Commission for its own services.

International Association of Deposit Insurers (IADI)

The International Association of Deposit Insurers (IADI) was formed in May 2002. The IADI is a forum for deposit insurers from around the world to gather to share knowledge and expertise to enhance the effectiveness of deposit insurance systems. It provides training and educational programs and produces research and guidance on matters related to deposit insurance.


KLE - key liquidity entities

In principle, for an entity or organisational form to be classified as a KLE, at least one of the three situations below should be expected in resolution: · the entity/organisational form is expected to provide liquidity to other resolution group entities in order for them to perform their activities; · the entity/organisational form is expected to depend on liquidity received from other resolution group entities to perform its activities; or · the entity/organisational form performs liquidity management functions for one or more entities of the resolution group.


Legal entities

As stated by the European Commission

Less-Significant Institutions (LSI)

Less significant institutions (LSIs) are banks that do not fulfil any of the significance criteria specified in the SSM Regulation – in contrast to significant institutions (SIs) that do fulfil at least one of them. The significance criteria relate to, among other things, a bank’s size, its importance to the economy of its home country or the EU as a whole, and the significance of its cross-border activities. In practice, the bulk of LSIs are smaller banks whose assets do not exceed €30 billion.


Liquidity refers to the efficiency or ease with which an asset or security can be converted into ready cash without affecting its market price. The most liquid asset of all is cash itself.


Material Legal Entities

Subset of group entities. The parent institution must always be included. Material group entities are the most significant entities within the group, whether that be due to the provision of critical funds or through generating a significant portion of the institution’s revenue.

Management Information System (MIS)

Management information systems are computer-based systems and procedures to gather
process and present information supporting the activities of a company. Management Information System are one of SRB’s Expectations for Banks aspects. MIS refer to the back office systems of an entity. Well-managed MIS ensure the delivery of timely, up-to-date and accurate information for the relevant valuations of an entity performed during resolution, and its communication framework and cooperation with authorities.

Member States

Member states of the European Union, as referred to by the European Union. July 2022, the EU counts 27 member states.

Minimum Requirement for own Funds and Eligible Liabilities (MREL)

MREL is the minimum amount of equity and unsecured debt a bank must set aside based on the amount of risk it takes, and which would be used to bail the bank in if it is to be resolved. MREL is set to help 1) carry out an effective resolution; 2) recapitalise a bank; 3) absorb losses. MREL serves to prevent a bank’s resolution from depending on public financial support. It helps to ensure a bank maintains sufficient own funds and eligible liabilities at all times to implement the resolution strategy. In the Banking Union, the SRB sets MREL for Sis.

Multi Annual Programme (MAP)

The SRB multi-annual work programme sets out the roadmap of the SRB’S policy aims and goals for the upcoming three years.

Multiple Points of Entry Resolution Strategy (MPE)

A multiple point of entry resolution strategy is an approach in resolution planning in which resolution powers are applied by two or more resolution authorities to different parts of the group. Under the MPE strategy, parts of the group could be separated in resolution and losses are absorbed by the relevant subsidiaries.


National Resolution Authorities

National Resolution Authorities (NRAs) are the resolution authorities in each Member State.

The NRAs are directly responsible for all banks which are not under the direct remit of the SRB. However, where it is necessary to ensure the consistent application of high resolution standards, the SRB can decide, or an NRA can request the SRB, to directly exercise all its powers with regard to banks falling within an NRA’s original remit.

National Competent Authorities

National Competent Authorities are the national supervisory authorities of the Member States participating in the SSM, as defined by the European Central Bank. National Competent Authorities are  in charge of banking supervision in participating countries.

Non-Performing Loans (NPLs)

A nonperforming loan (NPL) is a loan that is in default due to the fact that the borrower has not made the scheduled payments for a specified period. Although the exact elements of nonperforming status can vary depending on the specific loan's terms, "no payment" is usually defined as zero payments of either principal or interest.

No Creditor Worse Off (NCWO)

The No Creditor Worse Off principle states that no creditor of an institution should incur greater losses in resolution than they would have incurred under normal insolvency proceedings.


On-site Inspections (OSI)

On-site Inspections are in-depth investigations of risks, risk controls and governance at a bank. They follow specific procedures and are conducted at a specific point in time by a team which is led by a head of mission, who is independent from the team responsible for ongoing supervision – the Joint Supervisory Team (JST).

Operational Steps Documents (OSDs)

Operational Steps Documents (OSDs) are aimed at facilitating the enforcement of the resolution strategy and scheme at national level. This entails work on the operationalisation of all resolution tools, including transfer strategies (i.e. sale of business, bridge institution and asset separation vehicles).

Open Bank Bail-in

In accordance with Art. 27 (1) (a) SRMR.

Operational Plan

art of the Resolvability Work Programme that operationalises the programme through (i) concrete deliverables, (ii) timelines and (iii) milestones.

Operational Assets

An asset that is not a financial asset and that is required to perform relevant services, such as real estate; intellectual property including trademarks, patents and software; hardware; IT systems and applications; and data warehouses. Operational assets are critical/essential where access to them is required in order to perform a critical/essential service


Pari passu

The situation where two or more assets, securities, creditors or obligations are treated equally and managed without preference.

Plenary Session

Depending on the tasks, the SRB convenes in different compositions. The Plenary Session is composed of the Chair, the four further full-time Board Members and the Board Members representing all NRAs. Similar to the Executive Session, the Vice-Chair participates in the Plenary Session as a non-voting member, but carries out the functions of the Chair in their absence.

Post-resolution Business Reorganisation Plan (BRP)

A Business Reorganisation Plan (BRP), as required by Art. 52 BRRD, is based on ex-post insights into the cause(s), the concrete implications and circumstances of an institution’s failure. Within one month after the application of the bail-in tool to an institution or entity, the management body or the person or persons appointed in accordance with Article 72(1) shall draw up and submit to the resolution authority, a business reorganisation plan. Where the Union State aid framework is applicable, Member States shall ensure that such a plan is compatible with the restructuring plan that the institution or entity is required to submit to the Commission under that framework.

Preferred Resolution Strategy

Defined as in Art. 2 (3) Delegated Regulation 2016/1075.

Prior Permissions Regime

Banks need an authorisation under Articles 77 and 78a of Regulation (EU) 575/2013 (CRR) to redeem eligible liabilities, as of 27 June 2019. Article 78a(3) of the CRR provides for the development of regulatory technical standards (RTS) to specify certain elements of that authorisation.

To date, pending the RTS, the SRB applied a provisional procedure to assess and authorise banks’ applications, as clarified by the SRB Communication on SRB Permission Regime on Reduction of Eligible Liabilities published on 18 December 2020 and the SRB Communication on Application of RTS Provisions on Prior Permission for Reducing Eligible Liabilities as of 1 January 2022 published on 16 September 2021.

Public Interest Assessment (PIA)

The Public Interest Assessment is the main policy tool used to assess whether a failing bank should be resolved in the public interest, or whether it can be liquidated under normal insolvency proceedings.

To do this, the SRB assesses a number of elements, including the need to protect depositors, safeguard financial stability and minimise the use of public funds.


Ready for Crisis (R4C)

The SRB ICT’s platform for sharing secure and timely information in crisis cases with internal and external stakeholders.

Regulatory Technical Standards (RTS)

RTS are a set of technical compliance standards that, once endorsed by the European Commission, need to be met by all parties. The Regulatory Technical Standards cover topics such as data security and legal accountability. The RTS were developed by the European Banking Authority

Relevant Services

Services which underpin (i) the bank’s critical functions to the economy (critical services) and (ii) core business lines (essential services) for which continuity is necessary for the effective implementation of the resolution strategy. These categories may overlap. This applies analogously to operational assets and staff.

Relevant Staff

Employees of the parent or any group legal entity covering relevant roles.

Resolution Entity

A resolution entity means an entity established in the Union, which is identified by the resolution authority as an entity in respect of which the resolution plan provides for resolution action.

Resolution Group

A resolution entity and its subsidiaries that are not i) resolution entities themselves, or ii) subsidiaries of other resolution entities or iii) entities established in a third country that are not included in the resolution group in accordance with the resolution plan and their subsidiaries.

Resolution Reporting Requirements

Pursuant to Art.11(1) BRRD and Section B of the Annex to the BRRD, as well as Art.8(4) SRMR, the SRB collects information for drawing up and implementing resolution plans for banks under its remit. The SRB resolution reporting requirements (Liability Data Report, Critical Functions Report and FMI Report) cover the minimum information required by European Commission Implementing Regulation (EU) 2018/1624 of 23 October 2018 as well as further details required for the respective area.

Resolution Colleges

For banks headquartered in the Banking Union and with one or more subsidiaries or significant branches in one or EU countries outside the Banking Union, or vice-versa, Resolution Colleges bring the SRB and the relevant resolution authorities together to discuss and agree on resolution planning and other resolution matters. Depending on where the bank is headquartered, the SRB or the resolution authority of a country outside the Banking Union is the so-called Group-Level Resolution Authority (GLRA). The way in which Resolution Colleges are expected to work and the interaction among the members of the Resolution Colleges is defined in the Commission Delegated Regulation 2016/1075.

Resolution Committee (CoRes)

The Resolution Committee is the main platform for sharing experiences on resolution activities, so as to ensure consistency and highest standards of quality in resolution-related activities within the SRM.

In particular, the Resolution Committee’s tasks include addressing horizontal policy issues, developing guidelines and general instructions, identifying efficient approaches, analysing operational and data reporting issues so as to give IRTs the adequate toolkit for implementing standards and methodologies, supporting the development of the SRB oversight function towards LSIs, developing training activities to ensure consistency in resolution policies and activities across the SRM.

Resolution Planning Cycle (RPC)

The resolution planning cycle (RPC) is an annual process based on four phases leading to the approval of the updated resolution plan for each SRB bank. It includes the preferred resolution strategy, minimum requirements for own funds and eligible liabilities (MREL) and resolvability assessment.

It implements the requirements for the resolution planning of banks under direct remit of the SRB laid down in the SRMR and BRRD.

Resolution Planning Manual (RPM)

Serves as a guide for resolution-planning activities. It supports the SRB guidance of banks in their implementation of the Expectations for Banks (EfB), The RPM ensures the coherence between the common and bank-specific requirements, and consistency across banks.

The Resolution Planning Manual provides Internal Resolution Team (IRTs) with a best-practice guide for the resolution plans and resolution strategies, It has been amended to require a clear comply-or-explain approach when deviating from the established policies. This further ensures compliance with the rulebook, high standards and consistency in resolution planning for SRB banks.

Resolution Planning Office (RPO)

The RPO is operational at the SRB since summer 2020. It provides operational support concerning the planning and implementation of the RPC and coordinate the interaction of SRB functions for resolution planning purposes. It will monitor the RPC, gather and consolidate the views of resolution units on policy topics and contribute to promote consistent and high-quality resolution planning practices across SRB banks.

Resolution Steering Group (ReSG)

The Resolution Steering Group (ReSG) is one of the working groups of the Financial Stability Board (FSB) relevant for resolution in which the SRB participates.

The FSB has designated resolution regimes as one of the priority areas for implementation monitoring. The task of regular monitoring and reporting in this area is carried out by the FSB Resolution Steering Group (ReSG) and its subgroups, such as the Cross-Border Crisis Management (CBCM) groups for banks, insurers and financial market infrastructures. Their activities include monitoring progress and promoting the effective implementation in substance and scope of the Key Attributes of Effective Resolution regimes in the bank and non-bank financial sectors.

Resolution Tactical Team (RTT)

The Resolution Tactical Team is the SRB’s dedicated team in charge of coordinating crisis management at horizontal level. The Resolution Tactical Team (RTT) provides targeted guidance and support to bank-specific crisis management teams (CMTs), involving SRB and NRA staff, in order to promote consistent approaches and best practices.

Resolution Tools

If  a  bank  meets  the  relevant  conditions,  the  SRB  places  the  bank  under  resolution.  This  is  achieved by the adoption of a resolution scheme, which determines what resolution tools are to be applied to the bank and, if necessary, whether the SRF is to be used to support the resolution action. Before any resolution action is taken, the capital instruments of the bank must be written down or converted. The resolution tools are:

  • the sale of business tool;
  • the bridge institution tool;
  • the asset separation tool; and
  • the bail-in tool.

The relevant NRAs take the necessary steps to implement the resolution scheme.

Resolution Weekend

The resolution weekend is the second activity of the crisis management phase, which is subdivided into three phases, namely (i) the preparation for resolution, (ii) the “resolution weekend” and the implementation of the resolution scheme and (iii) the closing of the resolution.

The “resolution weekend” starts with the determination that an entity is failing or is likely to fail. While this phase refers to a weekend, this phase could start any time and covers all processes needed for the adoption of the scheme. The decision to adopt a resolution scheme must be implemented by the competent NRA. The weekend ends the next business day when relevant markets open. Depending on the tool(s) used, the possible business restructuring phase only starts thereafter.


The capacity of a bank or entity to fail in a safe manner. Instead of “too big to fail”, resolvability of a bank means it is “safe to fail”, not harming the financial stability and protecting the taxpayer from bail-out.

Resolvability Assessments Process (RAP) letter

A Resolvability Assessment Process (RAP) is conducted annually in respect of all G-SIBs (Global Systemically Important Banks) to promote adequate and consistent reporting on resolvability at a global level and to determine what should be done to address material recurring issues with respect to resolvability.

The assessment is conducted in Crisis Management Groups (CMGs), set up by the SRB. They execute the assessments for the global systemically important banks (G-SIBs) in the SRB’s remit.

The Resolvability Assessments Process (RAP) conducted in each CMG is summarised in a so-called ‘RAP letter’ addressed to the Chair of the FSB. The SRB is in charge of preparing such letters for all G-SIBs within its remit.

Resolvability Assessment

Resolvability assessment is a key component for measuring the credibility and feasibility to either liquidate the bank under normal insolvency proceeding or to resolve it by applying resolution tools.

The SRB expects banks to achieve full resolvability by the end of 2023 – i.e. to meet the MREL targets according to the determined schedule and to put in place all operational capabilities supporting the execution of their strategy. This resolvability assessment will be performed each year, and the main results will be subsequently published. The resolvability assessment is an iterative process over years.

Resolvability Progress Report

A document reflecting the progress made by the banks in addressing impediments, based on the Resolvability Work Programme. The report should: (i) give sufficient details on the banks’ deliverables against milestones and (ii) help IRTs to update the resolvability assessment at the end of each resolution planning cycle.

Resolvability assessment process (RAP)

A Resolvability Assessment Process (RAP) is conducted annually in respect of all G-SIBs to promote adequate and consistent reporting on resolvability at a global level and to determine what should be done to address material recurring issues with respect to resolvability.

The assessment is conducted in Crisis Management Groups (CMGs), set up by the SRB. They execute the assessments for the global systemically important banks (G-SIBs) in the SRB’s remit.

‘Restricted’ Executive Session

Depending on the tasks, the SRB convenes in different compositions. The ‘restricted’ Executive Session (or: Executive Session) is composed of the Chair and the four further full-time Board Members. The Vice-Chair participates in the ‘restricted’ Executive Session as a non-voting member, but carries out the functions of the Chair in their absence.

Relevant Roles

Job roles whose vacancy in resolution may present an obstacle to the continuity of critical functions and the core business lines needed for the effective implementation of the resolution strategy and any consequent restructuring.

Resolution-resilient features include the following:

  1. Non-termination, suspension or modification Service providers may not terminate, suspend or amend terms and conditions of service provision on the grounds of resolution/restructuring, provided that the substantive obligations under the contract continue to be performed.
  2. Transferability of the service provision Services can be transferred or assigned to a new recipient by the service recipient or the resolution authority because of resolution/restructuring.
  3. Support in transfer or termination In the case of transfer of service provision because of resolution/restructuring, the current provider should ensure the orderly transition of service provision to a new provider or to a new recipient, provided that the substantive obligations under the contract continue to be performed. Where required, including in the case of termination during resolution/restructuring, the provider should ensure continuity of service provision on the same terms and conditions for a reasonable period, e.g. 24 months.
  4. Continued service provision to a divested group entity Services can continue to be provided by the current intra-group provider to entities divested from the group as part of resolution/restructuring. Service provision should continue for a reasonable period following the divestment of the group entity, e.g. 24 months, provided that the substantive obligations under the contract continue to be performed.


Sale of Business

As defined in Art. 3 (1) (30) SRMR.


Separability is defined as the bank’s ability to implement a transfer of i) legal entities, ii) business lines, or iii) portfolios of assets and liabilities at short notice to a third party. Separability allows the SRB to execute, together with the national resolution authorities (NRAs), a market transaction within a reasonable amount of time, in order to ensure the resolution objectives through the bank’s transfer, in due course, to a private owner or through an orderly wind-down.

Securities Settlement System

A system that allows the transfer of securities, either free of payment or against payment (delivery versus payment). Significant Institution In accordance with Art.6(4) of Regulation (EU) No 1024/2013.

Single Point of Entry (SPE)

SPE is one resolution strategy handled by the SRB and defined by FSB Guidance and EU law.

SPE is the application of resolution powers at the parent level by a single resolution authority. Under SPE, the bank is resolved as a group and the parent absorbs group losses. The SPE strategy is more suitable for centrally structured and operational banks.

Under an SPE approach, only the resolution entity, i.e. the parent company, will be the direct target of resolution powers, and operational subsidiaries are preserved and would not themselves be subject to resolution. The SPE approach avoids the disruption caused by the application of resolution action, potentially by multiple authorities in multiple entities, within a group that is dependent on intragroup services and, at the same time, needs to acknowledge that most company, tax and insolvency laws focus on individual legal entities.

Single Resolution Fund (SRF)

The Single Resolution Fund (SRF) is an emergency fund that can be called upon in times of crisis. It can be used to ensure the efficient application of resolution tools for resolving the failing banks, after other options, such as the bail-in tool, have been exhausted. The SRF ensures that the financial industry as a whole ensures the stabilisation of the financial system. All banks across the 21 Banking Union countries must pay a fee annually by law to the SRF. These fees are called contributions. The Fund is being built up over eight years, from 2016 to 2023, and the target must, by law, reach at least 1% of the amount of covered deposits of credit institutions in the Banking Union.

The fund means that taxpayers are not first in line to pump money into a bank, should extra funding be required, since EU law requires all banks to pay into the fund annually.

Single Resolution  Mechanism (SRM)

The SRM is one of the pillars of the Banking Union, alongside the Single Supervisory Mechanism (SSM). As of November 2014, the SSM is the new system of banking supervision in the Banking Union, comprising the European Central Bank (ECB) and national supervisory authorities of the participating Member States (National Competent Authorities).

The Single Resolution Mechanism is made up of the Single Resolution Board and the National Resolution Authorities in Eurozone countries, Bulgaria and Croatia. It protects financial stability and the taxpayer by planning for and managing bank failures. The SRM is the second pillar of the Banking Union, providing centralised and independent decision-making on bank resolution, ensuring that the public interest and critical economic functions are protected.

Single Resolution Mechanism Regulation (SRMR)

The SRM Regulation was adopted in July 2014 to create an integrated decision-making framework for resolution in the Banking Union as a complement to the SSM, which pursues a similar objective with respect to supervision. The SRB works in close cooperation with the NRAs.

Single Rulebook

The Single Rulebook is a list of initiatives, pursued by the European Commission after the 2008 financial crisis in order to create a safer financial sector for the Single Market. The Single Rulebook aims to provide a single set of harmonised prudential rules which institutions throughout the EU must respect. They include:

  • stronger prudential requirements for banks;
  • improved protection for depositors;
  • rules for managing failing banks

Solvent wind-down (SWD)

For certain banks, the size and complexity of their trading books could impede the credible and feasible implementation of their resolution strategies. Solvent wind-down is an approach that can be used for exiting trading activities in an orderly manner and avoiding posing risks to financial stability. The lack of a credible SWD plan could jeopardise the credibility and feasibility of the resolution strategy of any bank with material trading books.

SRB Antifraud Strategy 2022-2024

The SRB Antifraud Strategy 2022-2024 is set up with the objective to mitigate fraud risks and preventing the occurrence of fraud. The Antifraud Strategy is overseen by the SRB Compliance.

SRB Financial Regulation

As defined in the Decision of the Plenary Session of the Single Resolution Board of 17/02/2020 on adopting the Financial Regulation of the Single Resolution Board. The SRB Financial Resolution sets five objectives, whose achievement is assured and monitored by the SRB Internal Control Framework (ICF). The five objectives are:

1) effectiveness, efficiency and economy of operations;

(2) reliability of reporting;

(3) safeguarding of assets and information;

(4) prevention, detection, correction and follow-up of fraud and irregularities, and

(5) adequate management of the risks relating to the legality and regularity of the underlying transactions, taking into account the multiannual character of programmes as well as the nature of the payments concerned.

SRM Legal Network

The Legal Network (LN) is a group of senior legal experts from the SRB and NRAs. The LN is the main platform for exchanging views, experience and expertise on legal matters that are relevant for the Banking Union. The LN aims also to gather and share knowledge on participating Member States’ national laws, in particular those implementing the BRRD.

The LN may discuss legal matters if requested by the SRB decision-making bodies or by the Chair of one of the SRB Committees. The Chair of the LN may also initiate discussions, provided that the scope of these terms of references is respected.

Strategic Business Analysis

The decision whether or not to resolve a bank and, if so, which functions to preserve, depends
on the bank’s characteristics. Hence in the first step of resolution planning, a detailed overview of the bank is produced: the strategic business analysis. The overview describes the bank’s structure, financial position, business model, critical functions, core business lines, internal and external interdependencies and critical systems and infrastructure.

The purpose of the strategic business analysis is to present these characteristics in a detailed overview to inform the determination of the preferred resolution strategy and resolvability assessment.

Standard contractual clauses (SCCs)

Referring to Standard Contractual Clauses for data transfer between EU and non-EU countries as stated by the European Commission.

Supply Side Analysis

A bank must identify its critical functions in the context of drawing up its recovery plan. To this end,

the bank must perform an ‘impact analysis’ and a ‘supply side analysis’. The supply side analysis focuses on the evaluation of the market for the provision of the function, in particular in terms of concentration and substitutability. It must be analysed whether the function can be substituted, i.e. whether it can be replaced in an acceptable manner and within a reasonable time frame thereby avoiding systemic problems for the real economy and the financial markets.

Substantive Impediments Procedure

The procedure described under Art. 10 SRMR. Synthetic Holding In accordance with Art. 1 (126) CRR.


Third country

A non-EU country.

Total Loss Absorbing Capacity (TLAC)

Total loss-absorbing capacity is an international standard, finalised by the Financial Stability Board (FSB) in November 2015, intended to ensure that global systemically important banks (G-Sibs) have enough equity and bail-in debt to pass losses to investors and minimise the risk of a government bailout.

Transfer strategies

Transfer strategies are reflected in minimum requirements for own funds and eligible liabilities (MREL) targets and closely relate to the SRB’s work on separability (see above).                                  

Trilateral Principals Level Exercise (TPLE)

The SRB takes part in a trilateral exchange on operational (rather than policy) issues with relevant UK and US authorities, which is calles the Trilateral Principals Level Exercise (TPLE). This collaboration project focuses on increasing the mutual understanding of domestic resolution frameworks, ensuring operational preparedness for cross-border resolution and cooperation with relevant authorities in the banking union, UK and US jurisdictions.

Transitional Service Agreement

An agreement that determines the scope (and other aspects) of services one company should provide to another when there is a change of ownership.


Valuation 1

Valuation 1 is the valuation required under Art. 20 (45) (a) SRMR to assess whether the conditions for resolution, or for write-down or conversion of capital instruments, are met.

Valuation 2

Valuation 2 informs the decision on the appropriate resolution action to be taken and, depending on that action, the decisions on the extent of the cancellation or dilution of instruments of ownership; the extent of the write-down or conversion of relevant capital instruments and eligible liabilities; the assets, rights, liabilities or instruments of ownership to be transferred; and the value of any consideration to be paid. It further ensures that any losses on the assets of the entity are fully recognised. Valuation 2 should include an estimate of the treatment that each class of shareholder and creditor would have been expected to receive if an entity were wound up under normal insolvency proceedings.

Valuation 3

Valuation 3 aims at determining whether or not shareholders and creditors would have received better treatment if the institution under resolution had entered into normal insolvency proceedings. In other terms, Valuation 3 aims at assessing any possible breach of the NCWO principle.

Virtual Data Room

A virtual data room is generally intended to be an online facility where documents and information to perform a due diligence are uploaded.