Minimum Bail-in Data Template: Current Developments and Solution Approaches
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Introduction
The Minimum Bail-in Data Template (MBDT) is a standardized data template package designed to ensure that banks can provide the necessary data for applying the bail-in tool in the event of a crisis. Its purpose is to support the application of write-down and conversion powers, harmonize and standardize data provision, and ensure legal clarity in the implementation of a bail-in.
The SRB conducted a public consultation on the MBDT between March and May 2024, and the MBDT documentation was finally published on November 5, 2024. This documentation includes:
Guidelines with instructions on the templates and fields to be reported
Templates in Excel format
Annex with technical instructions
Validation rules
Country-specific annexes
The templates to be reported are presented in the following table
Figure 1 Overview of MBDT Templates Including Indication of Implementation Effort
Due to differing legal regulations in EU countries, such as creditor hierarchies, national authorities may define additional data requirements.
These requirements are documented in specific country annexes.
Regarding Template B02.00, two separate submissions are expected from institutions in the context of bail-inable deposits:
Submission A: Aggregated information for bail-inable deposits and granular information for deposits that are treated pari passu or subordinate to senior non-preferred instruments in the insolvency hierarchy.
Submission B: Granular information on all bail-inable deposits.
The same applies analogously to Template B90.00.
Institutions have 12 months to adapt to the provision of bail-in data in the new format and update their Bail-in Playbooks accordingly. An additional 6-month implementation period applies to Templates B01.00, B03.00, B04.00, as well as Submission B of Templates B02.00 and B90.00.
Due to these transitional periods, the templates with the additional implementation timeline cannot be part of the Dry Runs scheduled for 2025.
Challenges
Most of the templates listed above require information that was already part of the LDR or the Bail-in Data Set—the predecessor of the MBDT—in a somewhat differently structured form.
However, there are certain aspects where data requirements should be technically and functionally examined at an early stage, including:
Details on received guarantees (Template B05.00), such as guarantee triggers, collateral status, and type of security
Information on collateral provided by third parties in Template B02.00 (e.g., particularly relevant for state banks: guarantor liability)
All data in the context of SPVs for the new Template B06.00: Agreements like Liquidity Asset Purchase Agreements may not be available in an automated form in the existing data structure
Additionally, to avoid complexity and ensure consistency, it is important to use a uniform data basis. This is especially relevant with the MBDT since the individual templates are interlinked: for example, business partners now need to be listed in Template B90.00 and referenced to the corresponding liability there. The same applies to the aggregated view in Template B01.00.
Solution Approaches
Providers of regulatory reporting software are currently planning to develop appropriate modules for generating the MBDT report.
Regnology is expected to provide a first version by the end of 2025. This represents a clear advantage compared to the previous Bail-in Data Set, where providers ruled out implementation. The reason for this shift is likely the standardization of the reporting format introduced with the MBDT.
Nevertheless, a complete solution through regulatory reporting software alone is unlikely, as there is a small number of data points not available in the respective data warehouse. This particularly applies to accounting data, such as balance sheet positions of liabilities, or other specific information, for example, whether bonds are New or Classical Global Notes.
To what extent a hybrid solution of regulatory reporting software and additional processing will be practical remains to be assessed as implementation progresses.
Alternatively, the collection of MBDT data can be automated using tools like Power BI, Tableau, etc. For clients where Finbridge developed tools for creating the Bail-in Data Set, the provision time for bail-in data was reduced from nearly 24 hours to just 4–6 hours.
In such a tool, the majority of data is taken from the regulatory reporting data warehouse, specifically from software like Abacus or BAIS, and combined with other necessary data (see above), such as accounting information, which is then loaded as input tables into the tool. Through predefined transformation logics, the corresponding templates can be generated at the push of a button. Additionally, validation rules, both those specified by regulators and custom-designed ones, can be automatically integrated.
Figure 2 Schematic Representation: MBDT Generation Using ETL Tools
The aforementioned issue regarding the assurance of consistency across the different templates can also be addressed through this application by introducing an intermediate layer in the data processing. This layer contains all relevant data from which the individual templates are generated.
This ensures, for example, that partners reported in Template B90.00 are not listed without corresponding liabilities in Template B02.00.
Additionally, the need for adjustments across various data streams becomes obsolete, as each data field is mapped only once to the central intermediate layer. For instance, partner information does not need to be supplied through different data streams for Templates B01.00 and B90.00.
Figure 3 Schematic Representation: Standardized Intermediate Layer for MBDT Template Generation
Finbridge as your Partner for Resolution Planning
Whether supporting the implementation of a new regulatory reporting software module or developing a customized tool to generate the MBDT report, Finbridge assists you throughout the process.
Our experts have experience working at institutions such as the Bundesbank, the SRB, and regulatory reporting software providers. They have been actively involved in the market with feasibility studies, trial calculations, and implementation projects related to bail-in data, resolution planning, and regulatory requirements in general, bringing many years of practical experience and expertise to support you effectively in meeting these challenges.
Thanks to our extensive knowledge in overall bank management, combined with broad, implementation-oriented practical experience in resolution planning, we can flexibly adapt to your needs and institution-specific requirements, guiding you until the expectations of the resolution authorities are fully met.
Do you have any questions about the detailed regulatory changes? Our experts are happy to support you with their specialized knowledge during your planning and implementation phases.
Authors: Raphael Steßl, Philip Bulut
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