7.6.5 Concluding remarks

It should be noted that the Crisis Communications do not explicitly mention ‘systemic importance’ as an assessment criterion. Rather, the assessment criterion is ‘serious disturbance in the economy’. Nevertheless, the Commission usually assesses the systemic importance of the bank, so the systemic importance is at least implicitly used as an assessment criterion. This is not surprising, since only banks with systemic importance can create a serious disturbance in the economy. However, since the Commission takes the view that in the situation of a financial crisis, every bank that collapses can create a serious disturbance, every bank is considered to have systemic importance. Consequently, the (implicit) assessment criterion ‘systemic importance’ is always met. This means that although the fact that the bank is systemically important is a relevant characteristic, it is not a distinguishing characteristic.1