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Supervision of Systemically Important Financial Institutions (SIFIs)

Central Banking and Monetary Policy November 30, 2025
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Introduction

The supervision of **Systemically Important Financial Institutions (SIFIs)** is a complex and high-stakes endeavor that requires specialized regulatory frameworks beyond standard microprudential oversight. This advanced course provides a detailed examination of the international policy agenda—driven by the **Financial Stability Board (FSB)**—for mitigating the "too-big-to-fail" problem. Participants will learn the methodologies for SIFI designation (G-SIBs and D-SIBs), the application of enhanced supervisory standards (e.g., higher capital buffers, stricter liquidity rules), and the crucial requirements for developing credible **Recovery and Resolution Plans (RRPs)** to ensure that SIFIs can fail safely without taxpayer bailouts.

Objectives

Upon completion of this program, participants will be able to:

  • Explain the "too-big-to-fail" problem and the international policy response.
  • Describe the methodologies for designating Global and Domestic SIFIs (**G-SIBs** and **D-SIBs**).
  • Analyze the enhanced regulatory requirements for SIFIs (e.g., higher capital, TLAC, enhanced supervision).
  • Evaluate the structure, content, and credibility of SIFI **Recovery and Resolution Plans (RRPs)** ("living wills").
  • Understand the legal and operational implementation of the **bail-in** tool in bank resolution.
  • Assess the effectiveness of cross-border supervisory colleges and cooperation agreements.
  • Identify and manage the specific governance, risk management, and operational risks of SIFIs.
  • Formulate policy recommendations to strengthen the national resolution regime for SIFIs.

Target Audience

  • Bank Supervisors and Regulatory Authority Personnel
  • Central Bank Financial Stability Analysts
  • Commercial Bank Risk Management, Compliance, and Resolution Planning Teams
  • Government Policy Makers on Financial Regulation
  • Internal Auditors specializing in Large Bank Supervision
  • Academics and Researchers in Financial Regulation

Methodology

SIFI designation scoring exercises, RRP review and critique group project, Case studies on historical resolution failures (e.g., Lehman), Policy debates on TLAC/MREL calibration, Role-playing resolution authority decision-making, Legal analysis of bail-in implementation.

Personal Impact

  • Master the complex international framework for SIFI supervision and resolution.
  • Acquire specialized knowledge in SIFI designation, TLAC/MREL, and capital surcharges.
  • Enhance analytical skills for assessing the credibility of Recovery and Resolution Plans.
  • Gain proficiency in the legal and operational mechanics of the **bail-in** tool.
  • Improve career prospects in large bank supervision, capital planning, and resolution.
  • Be able to contribute to mitigating the "too-big-to-fail" risk.

Organizational Impact

  • Ensure institutional compliance with all enhanced SIFI regulatory requirements.
  • Develop and maintain a robust, credible, and executable Recovery and Resolution Plan.
  • Strengthen governance, risk management, and controls to meet supervisory expectations.
  • Reduce the risk of systemic instability stemming from the organization's failure.
  • Improve the rigor of internal audit and risk assessment of SIFI-specific risks.
  • Facilitate effective cooperation with global supervisory colleges.

Course Outline

Unit 1: The SIFI Problem and Designation

Section 1: The Too-Big-To-Fail Problem
  • Defining systemic risk and the economic rationale for enhanced SIFI regulation.
  • The moral hazard and competitive distortion associated with implicit guarantees.
  • The international policy response: the G20/FSB agenda post-2008.
  • Criteria for evaluating a firm's systemic footprint (e.g., size, interconnectedness, complexity).
Section 2: SIFI Designation Methodology
  • The methodology for scoring and designating **Global SIFIs (G-SIBs)**.
  • National approaches for designating **Domestic SIFIs (D-SIBs)**.
  • Regulatory implications of SIFI designation (e.g., higher capital surcharges, liquidity rules).
  • Challenges in the supervision of non-bank financial institutions (NBFIs) as SIFIs.

Unit 2: Enhanced Prudential Requirements

Section 1: Capital and Loss Absorption
  • The application of the **G-SIB capital surcharge** and its calculation.
  • The requirement for **Total Loss-Absorbing Capacity (TLAC)** for G-SIBs.
  • The implementation and features of the minimum requirement for own funds and eligible liabilities (**MREL**) in other jurisdictions.
  • Analyzing the impact of these requirements on SIFI funding costs and structure.
Section 2: Enhanced Supervision and Governance
  • Regulatory expectations for SIFI risk governance, controls, and risk culture.
  • Requirements for enhanced public disclosure and transparency (e.g., stress test results).
  • The use of cross-border **Supervisory Colleges** for consolidated oversight.
  • Policy on separation of trading and retail activities (e.g., Volcker Rule, ring-fencing).

Unit 3: Recovery and Resolution Planning (RRP)

Section 1: Recovery Plans
  • The regulatory mandate for SIFIs to develop a credible **Recovery Plan** ("first line of defense").
  • Key components of a recovery plan (e.g., options for capital generation, liquidity measures).
  • The process of supervisory review and challenge of the recovery plan.
  • The **trigger points** for moving from recovery to resolution.
Section 2: Resolution Plans ("Living Wills")
  • The regulatory requirement for Resolution Authorities to develop **Resolution Plans** for SIFIs.
  • The preferred resolution strategy (e.g., Single Point of Entry, Multiple Point of Entry).
  • Legal and operational feasibility of executing the resolution strategy (e.g., separability, operational continuity).
  • The legal framework for the implementation of the **bail-in** tool.

Unit 4: Resolution Tools and Cross-Border Issues

Section 1: Resolution Tools
  • Mechanics of the **bail-in** tool: conversion and write-down of liabilities.
  • Use of other resolution tools (e.g., bridge institution, asset separation).
  • Ensuring continuity of critical functions (e.g., payment, custody, IT) during resolution.
  • Legal challenges related to creditor safeguards and judicial review.

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Upcoming Sessions

16 Feb

Barcelona

February 16, 2026 - February 20, 2026

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09 Mar

Washington DC

March 09, 2026 - March 13, 2026

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20 Apr

Munich

April 20, 2026 - April 24, 2026

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