Building operational capability for the Single Resolution Board's updated liquidity guidance

The Single Resolution Board's (SRB) consultation on its updated Operational Guidance on Liquidity and Funding in Resolution is more than a simple consolidation of rules; it is a targeted strengthening of operational expectations across liquidity estimation, measurement, and reporting, and collateral mobilization. By merging its frameworks into a single text, the SRB is making one thing clear: these are not separate compliance tasks. They are interconnected disciplines that form a single operational capability that banks must be able to demonstrate under crisis conditions.

The Technical Meeting on the Operational Guidance also clarified that the consolidation is intended to reduce duplication between EfB 3.1, 3.2, and 3.3 and to encourage the reuse of existing analyses, data, and frameworks where appropriate.

For banks, this means the era of treating resolution planning as a theoretical, "check-the-box" exercise is over. Let's break down what this means in practice.

• The fast-moving scenario is significantly shortened: Banks must model a scenario in which entry into resolution occurs within one month of crisis onset, compared with three months under the previous approach.
• Banks should also consider a variant resolution strategy where relevant, rather than modelling only the preferred resolution strategy.
• Group structures are under the microscope: Mapping Key Liquidity Entities (KLEs) remains critical, but branches, SPVs, and other entities are not automatically KLEs. Identification depends on their actual liquidity role, resolution-group structure, and proportionality.

• For institutions with a Multiple Point of Entry (MPE) strategy, each resolution group is expected to manage its liquidity independently.
• The SRB's Annex II template provides an optional blueprint for the expected data structure. Institutions may use their own systems and formats as long as they provide equivalent information effectively.
• KLE and KLD analyses do not necessarily need to be recreated in full every year; updates depend on material changes, resolution-plan updates, and IRT prioritization.

The SRB's answer is: within short notice, defined as a maximum of 24 hours. The Technical Meeting further clarified that this may require banks not only to extract existing figures, but also to update estimates and rerun relevant scenarios where assumptions or inputs change.

High-frequency capability means more than once per day, with the reference point as close as possible to submission. This does not imply continuous real-time reporting, but it does require high-frequency capabilities, including intraday information where relevant.

Liquidity data collection and capability testing exercises are therefore more than a fire drill: they assess whether a bank's data systems, MIS, governance, and escalation processes can produce accurate, complete, and timely information under pressure. The Joint Liquidity Template is strongly encouraged because it is used for both exercises and crisis purposes, although equivalent formats may be used.

The explicit link to BCBS 239 is a clear signal that data lineage, governance, accuracy, completeness, and timeliness matter as much as the final numbers. Manual workarounds may still be used where necessary, but proxies and manual steps must be documented and controlled.

For Reporting and Operations teams, this is a stark operational test. A 24-hour turnaround leaves little room for fragmented data sourcing, lengthy reconciliations or unclear ownership. The capability test is not only about speed; it is about proving that the bank has a robust, auditable and repeatable production process.