Atribute	Detail
Resolution Reporting Subject Matter	null
Guidance Documents	-
Taxonomy	-
Unique Identifier	QA2020-215

Question

We would need to know the full chain with each intermediary and FMI behind it. Is it possible to obtain this information in the FMIR and if so, how should the bank report?

Response

The FMIR allows to report only one intermediary to an ICSD (or other FMI). - When subsidiaries use a parent to access FMI services, the FMIR will typically include information on the subsidiary's use of the parent as intermediary, as well as information on the parent's use of FMIs and/or intermediaries for such services. - However, in a chain of intermediaries where the parent is an entity outside the remit of the SRB, the full chain is not visible. The IRT may ask the bank to also report the FMI participations of the third country parent and/or enquire about the full chain with the bank. Please also refer to PQA-588 and to the Operational Guidance on FMI contingency plans (on the SRB website under: https://srb.europa.eu/sites/default/files/srb_operational_guidance_for_fmi_contingency_plans.pdf): "When the parent of an institution or group within the Banking Union is located in a third country, the Banking Union institution or group is expected to develop a local FMI contingency plan that covers all critical and/or essential FMI services needed by the institution or group, irrespective of whether the FMI services are received through direct FMI memberships, group entities outside the Banking Union or third parties. Local FMI contingency plans should enhance the likelihood of maintaining access ahead of and during resolution, for example by including appropriate resolution-resilient clauses in contracts and establishing local capabilities for meeting financial or operational requirements."

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