QA2025-49- Retroactive reference date

Question

The definition of the reference date in the guidance mentions the possibility for the reference date to be in the future (ie §22 _ If the resolution authority requests that the data is provided_ *_before_* _the reference date etc.. _); can SRB confirm that the reference date cannot be a past date ? §22 of the MBDT guidance for reference: _ The reference date for providing the data is the close of business of the relevant entity on the business day determined by the resolution authority and notified to the relevant entity in the request. The close of business on that business day must be determined by the relevant entity itself and agreed with the IRT. If the resolution authority requests that the data is provided before the reference date, the timeframe for providing the data will commence at the close of business on the reference date. _

Response

The SRB would not expect the delivery of the MBDT with a retroactive reference date for Bail-in purposes. However, it is important the banks are in a position to retrieve data as of the last close of business available, namely if the Resolution authority requires data on Tuesday 13/05, banks should be in a position to retrieve data as of Monday 12/05 COB. The MBDT has also been incorporated in the Expectation on Valuation capabilities (EoVC), currently under public consultation. This includes the need to ensure the capability to produce the MBDT data at some predefined reference dates for valuation purposes, even if such dates fall in the past. Questions on the EoVC will be answered only after its final publication.

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