The Single Resolution Mechanism (SRM): operation and role of the CRU and FRU

At the heart of theUnion BancaireThe Single Resolution Mechanism (SRM) was set up to manage the failure of the largest banks in the participating Member States in a centralised and harmonised way. This mechanism, which is structured around the Single Resolution Board (SRB) and the Single Resolution Fund (SRF), represents a major step forward in building a more resilient European banking sector and aims to preserve financial stability without placing the burden of crises on taxpayers. Understanding its architecture and components has become essential for economic and financial players.

What is the Single Resolution Mechanism (SRM)?

The ESM is one of the key pillars of the Banking Union, complementing the Single Supervisory Mechanism (SSM), which entrusts the European Central Bank (ECB) with the prudential supervision of the main banks in the eurozone and other participating Member States. The fundamental objective of the ESM is to ensure efficient and coordinated management of bank failures, particularly for credit institutions whose collapse could generate systemic risks. It aims to avoid the use of public funds to rescue banks and to ensure that losses are borne first and foremost by the banks' shareholders and creditors, according to a well-defined hierarchy.

Regulatory framework: Regulation (EU) No 806/2014 (SRMR) and Regulation (EU) 2019/877 (SRMR II)

The cornerstone of the MRU is the Regulation (EU) No 806/2014 of the European Parliament and of the Council of 15 July 2014SRMR (Single Resolution Mechanism Regulation). This regulation lays down uniform rules and a uniform procedure for the resolution of credit institutions and certain investment firms in the context of the ESM and the ERF.. It gives the CRU primary responsibility for resolution decisions for entities under its jurisdiction.  

The regulatory framework has been strengthened and clarified by the Regulation (EU) 2019/877 of the European Parliament and of the Council of 20 May 2019known as SRMR II. It amends the SRMR, in particular as regards the loss-absorption and recapitalisation capacity (TLAC and MREL) of credit institutions and investment firms.. The aim of SRMR II is to further improve the resolvability of banks and ensure that they have sufficient capital and eligible liabilities to absorb losses and be recapitalised in the event of a crisis, without calling on public money.. These regulations apply directly in the Member States participating in the Banking Union.  

Scope: participating Member States, types of entities covered (directly by the CRU or national authorities)

The SRM applies to credit institutions established in Member States participating in the Banking Union.. These are the countries of the euro zone as well as EU Member States outside the euro zone that have chosen to join through closer cooperation..  

The SRMR precisely defines the entities that fall within its scope. These include:  

• Credit institutions established in a participating Member State. Unlike the MSU, there is no distinction based on size to determine the CRU's direct resolution competence for all these institutions.  
• Parent undertakings established in a participating Member State, including financial holding companies and mixed financial holding companies, where they are subject to consolidated supervision by the ECB.  
• Investment firms and financial institutions established in a participating Member State, where they are covered by the ECB's consolidated supervision of their parent undertaking.  

The division of tasks is clear: the CRU is directly responsible for the resolution of the largest banks (those directly supervised by the ECB) and cross-border groups.. For other, smaller banks, the national resolution authorities (NRAs) remain competent to draw up resolution plans and take decisions, but they do so within the harmonised framework defined by the MRU and in close cooperation with the CRU.. The CRU may, however, decide to exercise its powers directly if a resolution involves the use of the FRU.or if an NRA does not apply the rules correctly.  

Relationship with the BRRD directive

The MRU and its SRMR regulation are based on the harmonised principles and tools introduced by the Directive 2014/59/EU establishing a framework for the recovery and resolution of credit institutions and investment firmssaid BRRD (Bank Recovery and Resolution Directive). This directive, subsequently amended by BRRD II (Directive (EU) 2019/879)had to be transposed into national law in all EU Member States.. It provides a common "toolbox" for resolution authorities, including preventive measures (recovery plans and resolution plans), powers of early intervention and resolution instruments (sale of activities, bridge institution, separation of assets and internal bail-in)..  

The SRMR adapts and complements the BRRD for Member States participating in the Banking Union, by centralising decision-making at CRU level for entities under its jurisdiction.. Thus, where the CRU performs tasks or exercises powers which, according to the BRRD, are the responsibility of a national resolution authority, it is considered to be that national authority or, for cross-border groups, the resolution authority at group level.. This ensures consistency between the general BRRD framework applicable to the whole of the EU and the MRU's centralised decision-making system for the eurozone and participating countries.  

The Single Resolution Board (SRB): a key player in the resolution process

The Single Resolution Board (SRB) is the central authority of the Single Resolution Mechanism. It is responsible for ensuring the orderly resolution of failing banks with minimal impact on the real economy and public finances of participating Member States.

Status and independence: EU agency based in Brussels

The CRU is an independent European agency based in Brussels.. Its independence is a fundamental element in ensuring the integrity and effectiveness of the resolution process, protecting it from national political influence or other undue pressures.. Although it cooperates closely with the European Commission, the ECB, the European Banking Authority (EBA) and the national resolution authorities, the CRU takes its decisions autonomously within the framework defined by the SRMR.. He is directly accountable to the European Parliament and the Council of the European Union..  

Main tasks: resolution planning, resolution decisions for large banks and cross-border groups

The CRU has a broad remit, covering the entire banking resolution lifecycle for the entities under its direct jurisdiction. In particular, it is responsible for:  

• Drawing up resolution plans For each significant bank or banking group, the CRU prepares a detailed resolution plan. This plan anticipates failure scenarios and defines the most appropriate resolution strategy, including the choice of resolution tools and how to preserve the bank's critical functions.  
• Assessing the resolvability of banks The CRU analyses whether banks can be effectively and credibly placed in resolution. If obstacles to resolvability are identified (for example, an overly complex legal structure), the CRU has the power to require banks to take steps to remedy them.  
• Making resolution decisions When a bank under its jurisdiction fails or is likely to fail, and resolution is in the public interest, the CRU adopts the resolution plan. This includes the choice of resolution instruments to be applied (sale of activities, bridge institution, separation of assets, internal bail-in) and the conditions for their implementation.  
• Managing the Single Resolution Fund (SRF) The CRU is responsible for managing the FRU and decides how it is used to provide financial support for resolutions.  

Governance: plenary and executive sessions, composition

The governance of the CRU is structured to ensure effective and representative decision-making. Decisions are taken at two types of session:  

• Plenary sessions The meetings are attended by the Chairman, the Vice-Chairman, the four full-time permanent members and representatives of the national resolution authorities of all participating Member States. The ECB and the European Commission participate as observers. Plenary sessions deal with general issues, policy guidelines, the CRU budget and decisions relating to the URF, particularly when its use exceeds certain thresholds. Decisions are generally taken by simple majority, except for certain specific financial issues.  
• Executive sessions They are made up of the Chairman, the Vice-Chairman, the four permanent members and only representatives of the national resolution authorities of the Member States where the banking entity concerned by the specific resolution decision is established. The ECB and the European Commission are also observers. This more restricted format is dedicated to taking decisions specific to the resolution of a particular bank or group. Decisions are taken by consensus, but in the absence of agreement, the Chairman and the four permanent members decide by a simple majority.  

The Chairman of the CRU, currently Dominique Laboureix, directs the agency, prepares the work of the sessions and is responsible for day-to-day management.. He is assisted by a Vice-President and four other permanent members, all appointed after a rigorous selection procedure involving the Commission, the European Parliament and the Council of the EU..  

Specific powers of the CRU (investigation, inspections, sanctions)

The CRU has extensive powers to carry out its duties.

• Powers of investigation and inspection The CRU may require any person (credit institutions, their directors, etc.) to provide all the information needed to draw up resolution plans or take resolution decisions. It can conduct general enquiries and on-site inspections at banks' premises, examine books and records, and interview staff. In the event of obstruction, it may request the assistance of national authorities, including judicial authorities.  
• Penalty powers The CRU may impose financial penalties (fines) and periodic penalty payments on entities that fail to comply with their obligations under the SRMR. For example, refusing to comply with a CRU decision, obstructing an investigation or providing incomplete information may be sanctioned. Fines can amount to up to 1% of the total annual net turnover of the entity concerned, and periodic penalty payments are calculated on a daily basis. These penalties must be effective, proportionate and dissuasive.  

These powers enable the CRU to ensure compliance with the resolution framework and to have the necessary information and resources to act decisively in the event of a crisis.

The resolution decision-making process at European level

Managing a bank failure within the Banking Union involves a structured decision-making process, coordinating the actions of the CRU, the ECB, the European Commission, the EU Council and the National Resolution Authorities (NRAs).

Division of tasks between the CRU and the national resolution authorities

As mentioned above, the CRU is directly responsible for planning and implementing the resolution of "significant" credit institutions (those directly supervised by the ECB) and cross-border banking groups.. NRAs retain responsibility for the resolution of less significant institutions on their territory, unless the resolution of such an entity requires the use of the FRU, in which case the CRU intervenes.. The NRAs assist the CRU in carrying out its tasks, in particular in gathering information and implementing resolution decisions on the ground, in accordance with the national law transposing the BRRD directive.  

Resolution plans drawn up by the CRU

The CRU draws up a resolution plan for each bank or group within its remit.. This strategic document, which is updated at least once a year, anticipates the actions to be taken if the bank were to default.. It identifies the critical functions to be preserved, the preferred resolution strategy (e.g. sale of activities, internal bailout), the potential obstacles to resolution and the means of overcoming them.. These plans are drawn up in cooperation with the ECB and the NRAs concerned.. The establishment itself is required to provide all the necessary information to the CRU.  

Assessing "resolvability" and removing obstacles

At the same time as drawing up the plans, the CRU assesses the "resolvability" of each bank.. The aim is to determine whether, in the event of a crisis, the bank can be put into resolution in an orderly and efficient manner, without spreading risks excessively and without recourse to public funds.. This assessment takes into account the bank's legal and operational structure, its complexity, the availability of information, etc..  

If the CRU identifies substantial obstacles to resolvability (for example, a group structure that is too opaque, excessive interdependencies, an inability to value certain assets quickly), it must inform the bank.. The company has a period of time in which to propose corrective measures.. If the proposals are deemed insufficient, the CRU has the power to impose specific measures on the bank to remove these obstacles.. These may include the obligation to simplify its legal structure, to dispose of certain assets, to limit certain activities, or to set up a parent financial holding company..  

Triggering resolution: role of the ECB and the CRU

A resolution procedure is only initiated if several cumulative conditions are met, in accordance with article 18 of the SRMR. Firstly, the ECB (or the competent NRA for less significant banks) must find that the institution is "failing or likely to fail" (failing or likely to fail - FOLTF). This assessment is based on precise criteria, such as substantial losses that have absorbed all or a significant part of the company's equity capital, a situation of proven or imminent insolvency, or the need for exceptional public financial support..  

Secondly, there must be no reasonable prospect that any other measure (e.g. private sector action or supervisory action) could prevent the failure within a reasonable time.. Thirdly, a resolution measure must be necessary in the public interest. In other words, resolution must be preferable to a normal insolvency procedure in order to achieve the objectives of financial stability, continuity of critical functions and protection of depositors and public funds..  

It is the CRU which, after receiving the FOLTF notification from the ECB (or the ANR), determines whether conditions two and three have been met and whether a resolution procedure should be initiated.

Adoption of the resolution mechanism: interaction with the Commission and the Council of the EU

Once the CRU has decided that a resolution is necessary and has defined a resolution plan (including the instruments to be used and possible recourse to the FRU), this plan must be sent to the European Commission for approval.. In particular, the Commission verifies the compatibility of the scheme with EU State aid rules if the RUF is used or if public support is envisaged.. The Commission has a very short period of time (in principle 24 hours) in which to approve the scheme or object to it..  

If the Commission approves, or if it does not object within the time limit set, the mechanism is deemed to have been adopted. However, the Council of the EU may, in exceptional circumstances and by a simple majority, object to the measures proposed by the CRU or ask for them to be amended if it considers that the use of the RUF above a certain threshold (€5 billion) or the granting of State aid is not appropriate, or if the resolution has significant budgetary implications for a Member State.. This process underlines the balance of power between the technical resolution authority (CRU) and the EU's political institutions.  

Implemented by national authorities under CRU instructions

Once the resolution mechanism has been adopted at European level, its practical implementation on the ground is ensured by the competent NRAs, acting under the direct instructions of the CRU.. The NRAs use the powers conferred on them by their national legislation (transposing the BRRD) to apply the measures decided by the CRU (for example, organising the sale of assets, setting up a bridge institution, notifying the creditors concerned by an internal bailout).. The CRU closely supervises this implementation and the NRAs must report regularly to it on the progress of operations..  

Resolution instruments implemented by the CRU

To manage the failure of a bank, the CRU has a range of resolution instruments, broadly defined by the European Commission. BRRD directive and specified in the SRMR. These tools are designed to ensure the continuity of the bank's essential functions, protect depositors and minimise the impact on financial stability and public finances.. The CRU may decide to use these instruments alone or in combination.  

Coordinated application of BRRD tools (sale, bridge institution, asset segregation, internal bail-in)

The CRU applies the four main resolution instruments provided for in the BRRD in a coordinated manner:  

• The sale of businesses (or sale of business) This instrument consists of transferring shares issued by the institution in resolution, or all or part of its assets, rights and liabilities, to a private buyer. The purchaser must have the necessary authorisations and the transaction must be carried out under market conditions that are as transparent and non-discriminatory as possible, while allowing rapid action. The consent of the shareholders of the selling institution is not required.  
• The relay facility (or bridge institution) This involves temporarily transferring all or part of the sound activities of a bank in resolution (assets, rights, liabilities) to an entity controlled by the public authorities (the bridge institution). The aim is to maintain critical functions and then to enable the bridge institution (or its assets) to be sold to the private sector under favourable conditions. The bridge institution must obtain approval and operate with a view to a future sale.  
• The separation of assets (or asset separation tool) This tool is used to transfer "toxic" assets or assets that are difficult to value from a bank in resolution to an asset management structure (often referred to as a "special purpose vehicle"). bad bank). This helps to clean up the balance sheet of the residual bank (or bridge institution) and facilitate its resolution or sale. This instrument is generally used in conjunction with another resolution instrument.  
• Internal replenishment (or bail-in) This is one of the most innovative instruments. It aims to absorb the bank's losses and recapitalise it by using the bank's internal resources, i.e. by imposing losses on its shareholders and some of its creditors, according to a strict order of priority. Equity is the first to absorb losses, followed by subordinated debt instruments and, if necessary, certain senior unsecured debt. Covered deposits (up to €100,000) are protected and cannot be subject to internal bail-in. The aim is for creditors whose investments have contributed to the bank's risk to bear the losses before taxpayers. The application of bail-in is accompanied by the obligation for the bank to present a plan for the reorganisation of its activities.  

Impairment and conversion of equity instruments and eligible liabilities

Prior to, or concurrently with, the application of a resolution instrument, the CRU has the power to require the write-down (reduction in nominal value to zero) or conversion into equity (usually ordinary shares) of the relevant capital instruments and, if necessary, certain other eligible liabilities.. This makes it possible to absorb losses and facilitate the recapitalisation of the entity or the implementation of other resolution measures..  

The order in which losses are charged is strictly hierarchical:  

1. Tier 1 capital instruments (CET1), mainly ordinary shares.  
2. Additional Tier 1 capital instruments (AT1).  
3. Tier 2 capital instruments (T2).  
4. Other subordinated liabilities that are not AT1 or T2 instruments.  
5. Remaining eligible liabilities, according to the hierarchy of claims in the event of normal insolvency proceedings, while excluding certain liabilities such as covered deposits.  

This write-down and/or conversion is an essential step in ensuring that shareholders and subordinated creditors bear the losses before any intervention by the FRU or taxpayers.

Resolution strategies: single point of entry (SPE) vs multiple points of entry (MPE)

When planning the resolution of a banking group, the CRU must define a resolution strategy. There are two main approaches:  

• Single Point of Entry (SPE) strategy In this approach, resolution is applied at the level of the group's parent (holding) entity. The losses of the operating subsidiaries are transferred to the parent entity, which is then recapitalised (often by internal bail-out of its own debt instruments) or placed in resolution. In this way, the operating subsidiaries can continue their activities with limited impact. This strategy is often favoured by large integrated banking groups.  
• Multiple Point of Entry (MPE) strategy In this case, several entities within the group (for example, major subsidiaries in different countries) may be designated as entry points for resolution. Each entry point may be subject to a separate resolution procedure. This approach may be more appropriate for banking groups that are less integrated or have subsidiaries with a high degree of autonomy and local systemic importance.  

The choice of strategy depends on the structure of the group, its risk profile, its resolvability and the objective of minimising the impact on financial stability in the various jurisdictions in which the group operates. SRMR II introduced the concepts of "resolution entity" and "resolution group" to better identify the entities to which resolution measures would be applied under these strategies..  

The Single Resolution Fund (SRF): financing resolution

The Single Resolution Fund (SRF) is a central element of the ESM, designed to provide financial support for resolution measures where necessary to ensure their effectiveness and protect financial stability.

Objective: to provide financial support for resolutions without excessive recourse to public funds

The main objective of the FRU is to have a common financial capacity to help finance the resolution of failing banks under the MRU, without recourse to taxpayers' money or only as a last resort.. The FRU may intervene to guarantee certain assets or liabilities of a bank in resolution, grant loans, acquire assets or contribute to the capital of a bridge institution or an asset management structure.. However, it cannot be used to absorb a bank's losses directly or to recapitalise it in place of shareholders and creditors (except under very strict conditions as part of an internal bailout)..  

Constitution and target level: ex-ante contributions from banks, gradual mutualisation

The URF is financed by compulsory contributions paid by credit institutions and certain investment firms in the Member States participating in the URM.. These contributions are known as ex-anteThis means that they are collected annually before any crisis occurs.. The amount of each bank's contribution is calculated on the basis of its liabilities (excluding equity capital and covered deposits) and adjusted according to its risk profile..  

The FRU was set up gradually over an eight-year transition period, from 2016 to the end of 2023.. During this period, national contributions were gradually pooled. Initially, the funds were largely compartmentalised at national level, then the common share increased each year to reach 100% at 1 January 2024.. The target level of the URF is at least 1% of the amount of covered deposits of all credit institutions authorised in all participating Member States.. Initially estimated at around 55 billion euros, this target amount is now closer to 80 billion euros due to the increase in deposits covered..  

In the event of insufficient funds ex-anteThe FRU can also raise contributions ex-post with banks after a resolution, or resort to other forms of financing such as borrowing.  

Use of the FRU: conditions and limits (guarantees, loans, indirect recapitalisation)

The use of the FRU is strictly regulated. The CRU may decide to use the FRU to facilitate the application of resolution instruments, for example to:  

• Provide guarantees on the assets or liabilities transferred.
• Grant loans to the institution subject to resolution, a bridge institution or an asset management structure.
• Acquire assets of the institution in resolution.
• Make capital contributions to a bridge institution or asset management structure.
• Compensate shareholders or creditors if they have suffered greater losses than they would have incurred in a normal liquidation (the "No Creditor Worse Off" principle).  
• Contribute to a resolution under the internal bail-in instrument, but only if shareholders and creditors have already contributed at least 8% of the institution's total liabilities, in which case the FRU's contribution is limited to 5% of total liabilities.  

There are limits to the use of the UFR to avoid moral hazard. In particular, it cannot be used to cover losses that should have been absorbed by shareholders or creditors.

Interaction with national deposit guarantee schemes

The national deposit guarantee schemes (DGS) remain in place and their main task is to reimburse covered depositors (up to €100,000 per depositor per bank) in the event that their deposits become unavailable.. There is an interaction between the FRU and the SGDs. In the event of resolution, the DGS of the Member State concerned may be required to contribute to the financing of the resolution instead of reimbursing depositors directly, but its contribution may not exceed the amount of the losses it would have incurred if the bank had been wound up under a normal insolvency procedure.. If the SGD contributes to a resolution that also uses the FRU, their interventions must be coordinated. The objective is to ensure the protection of the depositors covered in the most efficient way.  

Financing the CRU itself: separate administrative contributions

It is important to distinguish between the financing of the FRU (intended for resolution operations) and the financing of the administrative operation of the CRU. The administrative expenses of the CRU (salaries, premises, IT systems, etc.) are covered by separate contributions paid by the same institutions that fund the FRU.. The CRU's administrative budget is adopted annually at a plenary session..  

Cooperation and recourse

The effectiveness of the ERM relies on close cooperation between the various authorities involved, at both European and international level. At the same time, appeal mechanisms are in place to guarantee the legality and proportionality of the decisions taken.

Cooperation within the MRU (ECB, national authorities, EBA)

Fluid and constant cooperation is essential between the CRU, the ECB (as supervisor and for its role in triggering resolution), the national resolution authorities (NRAs) and the European Banking Authority (EBA)..  

• CRU and ECB The ECB informs the CRU when a bank is failing or likely to fail. The two institutions work closely together to prepare resolution plans and assess resolvability. Memoranda of Understanding formalise this exchange of information and coordination.  
• CRU and ANR The NRAs assist the CRU in gathering information, drawing up resolution plans for less significant banks and implementing resolution decisions taken by the CRU in their territory. For cross-border groups, colleges of resolution authorities, chaired by the CRU, are set up to coordinate actions.  
• CRU and ABE The EBA plays an important role in the development of technical standards and guidelines that underpin the operation of the CRU (e.g. on the content of resolution plans, MREL, etc.). The EBA participates as an observer in CRU sessions and can play a mediating role in the event of disagreement between authorities within resolution colleges. The CRU informs the EBA of its decisions and the sanctions imposed.  

Cooperation with third countries (agreements, recognition of procedures)

As large banks often operate on a global scale, cooperation with resolution authorities in non-EU countries is essential to effectively manage the failure of international banking groups. The CRU (representing the NRAs of participating Member States) may conclude non-binding framework cooperation agreements (Memoranda of Understanding) with the authorities of third countries to facilitate:  

• The exchange of confidential information.  
• Coordination in the development of resolution plans for international groups.  
• Mutual recognition of resolution procedures.  

The BRRD and SRMR include provisions for the recognition and enforcement of third-country resolution proceedings concerning assets or entities located in the EU, subject to certain conditions (compatibility with national law, no negative impact on EU financial stability, equivalent treatment of creditors).. Conversely, EU resolution authorities may exercise their powers over entities located in third countries, if cooperation so permits.. Agreements have been signed, for example, with the US (FDIC), UK (Bank of England) and Swiss (FINMA) authorities..  

Right of appeal against CRU decisions (Appeals Committee, CJEU)

To ensure the legality and fairness of decisions taken by the CRU, an appeals system is in place. Decisions taken by the CRU (for example, those relating to obstacles to resolvability, MREL requirements, sanctions, or contributions to the FRU) may be appealed to a court. Appeals Committee internal to the CRU. This committee is made up of five members and two independent alternates, appointed by CRU but not employed by it, with recognised expertise in the following areas. The appeals procedure is written and oral, and the Appeals Committee may confirm the CRU's decision or ask it to modify it..  

The decisions of the Appeals Committee, or the decisions of the CRU if recourse to the Appeals Committee is not possible or has been exhausted, may then be challenged before the Court of Justice of the European Union (CJEU). The CJEU is the ultimate body for ruling on the legality of the acts of EU agencies. The CRU is required to comply with the Court's rulings.. This dual level of appeal is intended to ensure effective judicial review of the CRU's actions.  

The Single Resolution Mechanism, with the CRU as the orchestrator and the FRU as the financial safety net, constitutes a complex but essential architecture for strengthening the resilience of the European banking sector and protecting taxpayers. Good coordination between these European bodies, national authorities and international partners, as well as respect for procedures and rights of appeal, are crucial to the success of the Single Resolution Mechanism. the general framework for bank resolution. If you are faced with a situation involving European banking law and its implications for resolution, the assistance of lawyers with a practice dedicated to these issues is essential. For an in-depth analysis of your situation and tailored advice, do not hesitate to contact our firm to discuss your options and benefit from our expertise in banking law.

Sources

• Regulation (EU) No 806/2014 of the European Parliament and of the Council of 15 July 2014 establishing uniform rules and procedure for the resolution of credit institutions and certain investment firms under a Single Resolution Mechanism and a Single Banking Resolution Fund, and amending Regulation (EU) No 1093/2010.
• Regulation (EU) 2019/877 of the European Parliament and of the Council of 20 May 2019 amending Regulation (EU) No 806/2014 as regards the loss-absorbing capacity and recapitalisation of credit institutions and investment firms.
• Directive 2014/59/EU of the European Parliament and of the Council of 15 May 2014 establishing a framework for the recovery and resolution of credit institutions and investment firms and amending Council Directive 82/891/EEC and Directives of the European Parliament and of the Council 2001/24/EC, 2002/47/EC, 2004/25/EC, 2005/56/EC, 2007/36/EC, 2011/35/EU, 2012/30/EU and 2013/36/EU and Regulations (EU) No 1093/2010 and (EU) No 648/2012 (for background and tools).  
• Intergovernmental agreement on the transfer and mutualisation of contributions to the Single Resolution Fund.