However, at this stage the hard buffer requirements set by the BRRD seem to be a more important driver than
the (proposed) TLAC requirements. Figure 11 plots the YTD share of covered bond funding as percentage of
the total funding attracted by the different banking jurisdictions in relationship to the previously calculated
TLAC and MREL shortfalls. Institutions from jurisdictions with comparatively lower Tier 1 and subordinated
buffers as percentage of their total assets (as approximation to the BRRD loss absorption definition) attract
less funding via covered bonds and vice-versa. The relationship with the TLAC shortfall points in the opposite
direction. This is not surprising as the TLAC requirements are at this stage still proposals. Furthermore, the
denominator effect, i.e. the differences between risk-weighted assets versus total assets (as proxy for liabilities
including own funds) offers an important explanation. In light of last year’s Basel Committee’s proposals on
risk-weighted assets, the ultimate liability management effects arising from TLAC loss absorption requirements
may already for that reason converge with the applicable BRRD bail-in buffer considerations.
That said, we think it is abundantly clear that issuance prospects for covered bonds will remain affected by the
banking community’s focus on bail-in buffers. Furthermore, for banks the current funding cost environment
is something of a sweet spot for the more expensive non-collateralised refinancing sources. Banks do well
to keep their valuable collateral powder dry, rather than issuing covered bonds to obtain a few basis points
cheaper funding.