Regulatory Alerts2015-09-23
Added · Updated
Q&A on Prior Assessment of AT1 and T2 Instruments
Institutions are not required to submit Additional Tier 1 (AT1) or Tier 2 (T2) instruments for prior supervisory assessment before issuance, a rule applying to both significant institutions under ECB supervision and less significant institutions supervised by DNB. While retrospective disqualification remains possible, the regulator encourages preliminary assessments for new or complex instruments, requiring documentation such as prospectuses, term sheets, and compliance analyses with the CRR and EBA standards. For non-complex follow-up issuances, a simple notification of completion suffices, though institutions must also ensure compliance with resolution authority requirements.