In this paper we present how French authorities have addressed key legal challenges and obstacles related to the resolution of cooperative groups, in particular the implementation of the bail-in tool (“individual bail-in” and “coordinated bail-in”).
In the first part, we present key features of French cooperative groups and the legal framework establishing a solidarity mechanism and central bodies. We also explain how we took into account the lessons learnt from previous crises, where it appears that French cooperative groups were resilient.
In the second part, we identify key challenges related to the implementation of the bail-in tool for cooperative groups and describe amendments made to the French legal framework on the occasion of the transposition of BRRD2, in order to clarify the legislation and facilitate the implementation of resolution strategies suited to cooperative groups.
In the last part, we point out progresses that should be made in order to achieve (i) a smooth operationalisation of the bail-in tool and (ii) the resolvability of French cooperative groups. Those elements and expectations are not specific to French cooperative groups, but should be considered as expectations to achieve a full resolvability of French cooperatives groups and are more generally in line with the FSB roadmap to make specific banks and large banks fully resolvable.