On 21 November 2014 the draft Dutch Implementation Act for the European Framework for the Recovery and Resolution of Banks and Investment Firms (the "Implementation Act") and draft guidelines were published for public consultation purposes. The Implementation Act is designed to implement the Bank Recovery and Resolution Directive ("BRRD") and to apply the Single Resolution Mechanism ("SRM").
This newsletter outlines how the Implementation Act in its current consultative form provides for implementation and application of the rules in the BRRD and the SRM with regard to early intervention, resolution and legal protection.
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