On 23rd November 2016, the European Commission released a package of banking legislation reforms. Some of these were expected – in particular those related to the minimum requirement for eligible liabilities and own funds (MREL) under the Bank Recovery and Resolution Directive (BRRD) and the implementation of the Financial Stability Board’s (FSB) total loss absorbing capacity (TLAC) principles into the MREL requirements. Other changes, however, have been less telegraphed, such as the proposed new requirement for non-EU banks with a large European Union (EU) presence to establish intermediate financial holding companies within the EU.

We have set out below a high level overview of some of the key changes being introduced by the proposed reform package.