Two returns, two questions

RESOL 1 asks what the bank owes and to whom, so that a plan can be written and a requirement calibrated. The MREL/TLAC return asks whether the requirement is being met right now. They overlap in subject and differ in purpose, which is why they have different frequencies, different legal bases and — for the eligible liability layer — different levels of detail.

For global systemically important institutions the same return carries TLAC, the FSB standard written into the CRR: Article 92a sets the requirement and Articles 72a to 72l define what counts. For everyone else in scope it carries MREL as set by the resolution authority, including any subordination requirement.

Reporting and disclosure are not the same obligation

The same implementing regulation covers two things that are easy to conflate: reporting to the authority and public disclosure. What a bank discloses is a subset, published on its own timetable, and it is the reason a site like this one can show anything about MREL stacks at all — the reported detail is confidential.

Where the instruments come from

The eligible liabilities reported here are the same instruments the instruments database tracks from public sources: the senior non-preferred, Tier 2 and Additional Tier 1 issues whose eligibility depends on maturity, governing law and the absence of acceleration rights. In the annual return the same population appears in Z 12.00, instrument by instrument.

The public part of this picture — issuance by class, by issuer and by maturity — is explorable in instruments and maturities.