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We set out suggestions for simplifying the UK’s MREL regime as part of the post-Brexit policy shape-up. We focus our attention mainly on the logical construction of MREL, the components of MREL, the thresholds for Bail-in and Partial Transfer resolution strategies (including the definition of transactional accounts) in the context of MREL, the quantum/calibration of the MREL requirement, and the impact of MREL on effective competition in the UK banking sector.

Further, whilst we express our full support for a robust bail-in regime as part of the prudential framework, MREL should ideally only apply to systemic firms (G-SIBs and D-SIBs).  However, in the event that it continues to be applied more widely than that, there should be real proportionality built in (e.g. around the thresholds and calibration).