12.3.3.1 Limited possibilities for burden-sharing

Sometimes, the possibilities for burden-sharing are limited. This can be the case if there are just no subsidiaries to divest, or if divesting those subsidiaries would endanger the bank’s viability. An example of the first situation can be found in the case of the (Cypriot) Cooperative Central Bank (CCB):

Other examples of a limited possibility to downsize are the cases of ATE, T Bank and Commerzbank. In the decision on T Bank, the Commission noted that T Bank was a very small bank: “It owned no stand-alone subsidiaries or business of sufficient size to be sold separately to contribute to the cost of the restructuring”.2 Similarly, in the decision on the Greek bank ATE, the Commission considered that “in view of the fact that ATE is mainly a retail bank that has no large bond portfolios to reduce but a medium-sized balance sheet consisting mainly of loans, the present downsizing is significant”.3 In the decision on Commerzbank, the Commission noted that “Commerzbank is not in a position to sell off further assets to reinforce its capital base in the short term without jeopardising its survival in the long term”.4