Da JPM
One area of uncertainty is that currently BRRD (as
proposed by the Council) only calls for privatesector
bail-ins to begin in 2018. The European
Parliament (EP) has proposed a start date of 2016,
while some policymakers (such as the ECB’s Jörg
Asmussen and Erkki Liikanen) have begun calling
for full phase-in starting in 2015, given the advent of
SSM and the targeted January 2015 start date of
SRM33. Risk is skewed towards an earlier start date
for full implementation of BRRD bail-in policy, in
our opinion, although it is unlikely to be
implemented before the SRM start date, which is at
risk of delay past 2015, in our opinion. There is also
risk of earlier application in individual countries on a
selective basis