1. Recovery Options: Analysis Observations
List and description of recovery options
Recovery options (disposal, capital raising, cost reduction):
Have timeframes not well settled,
Lack of a clear articulation of the phases needed to implement each option,
Probably assumptions have not been internally validated.
The options are not defined in relation to different scenarios. E.g. business as usual markets vs stressed markets
Impact assesment
The plan has deficiencies/ lacks of :
The same discount level for disposal for all subsidiaries and reasoning is not included in the plan.
More precise data for each option such as the potential purchasers, sales valuation.
The information available is insufficient to understand the valuation of liquidity and capital impact of each option.
The past experiences in capital raising are not in the same context (very optimistic and not considering market stressed situations and other issuing limitations (dilution, extraordinary shareholders agreement or the scenario in a systemic crisis in the banking sector).
The timeframe for issuing, can be altered in adverse market conditions.
The impact of the issuance (4,2% CET1) in capital may need further detail.
They are not defined any actions to mitigate the impediments/obstacles.
The cost reduction measures do not define the impact of each measure in economic terms.

2. Recovery Options: Analysis Observations Feasibility assessment
The plan has deficiencies/ lacks of :
Should provide a more detailed timeframe description
The plan needs to describe better the potential impediments and offer feasible remedial actions for them.
Material deficiencies identified are not addressed (shareholders agreements, operational interdependency, etc..)
The disposal option of Bank Compass, as it provides a critical function, can severely damage the entire group, and the substitution/transfer to another entity of the group of the critical function that provides this subsidiary is not easy or quick. It will cause an operational impact. Also, it is not adequate with the business strategy and description of critical functions
The Bank Card subsidiary provides a critical function as it is identified in the plan (page 14), so the disposal of this subsidiary is not feasible or credible
The plan should include a detail description of under which circumstances the disposal of Bank Compass or Bank Card option can maintain the viability of the institution and restore its financial soundness.
The plan lacks of the sufficient steps that describe each option, and also the precise timeframe for each of the options. Also the needed preparatory measures for each option are not defined.