Bank recovery plan · CEMAC banking resolution regulation
Your recovery and resolution arrangements, measured and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Bank recovery plan · CEMAC banking resolution regulation
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One CEMAC Regulation on the treatment of credit institutions in difficulty and banking resolution assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism (a level, the level above, and the action that connects the two) that turns a finding into a trajectory.
Are the recovery plan’s trigger indicators calibrated, monitored and linked to an escalation procedure?
- N1
No trigger indicators are defined. Routine prudential monitoring does not distinguish thresholds that would call for activation of the plan.
- N2
A list of indicators appears in the plan, with thresholds taken from the regulatory minimum. Calculation is ad hoc and no procedure specifies what follows a breach.
- N3
Indicators are calculated at a set frequency and presented to the risk committee. An escalation procedure exists and names those responsible, with indicative timeframes.
- N4
Thresholds are calibrated against scenario projections and integrated into the management dashboard. Any breach triggers a tracked decision, including the decision not to activate the plan, and notification to the authority is prepared.
- N5
Calibration is reviewed periodically in light of crisis exercises, changes in the risk profile and supervisory findings. Revisions are documented and their effects measured.
Action to move from L2 to L3
Integrate the trigger indicators into monthly risk reporting, formalise an escalation note naming the person responsible for identifying a breach, the timeframe for convening the crisis committee and the recipient of the notification, then have it approved at the next risk committee meeting.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon CEMAC.
What this framework covers
The CEMAC framework for handling credit institutions in difficulty is built around three stages: prevention, early intervention and resolution. Prevention rests on the preventive recovery plan, a document the institution drafts, updates and submits to the Central African Banking Commission (COBAC). It sets out monitoring indicators, trigger thresholds, capital and liquidity recovery options, possible disposals, the stress scenarios retained and the decision chain that activates them. Resolution, by contrast, is a matter for the authority: the institution must supply it with the information that makes resolution workable, in particular on critical functions and group interdependencies.
In practice, the recovery plan runs into three difficulties. The first is the credibility of the options: has an asset disposal included in the plan been costed, tested against a plausible buyer, and its execution timeline verified? The second is alignment with day to day steering: are the trigger indicators the same ones tracked on the committee dashboard, or a separate list updated once a year? The third is governance: who identifies a breach of a threshold, within what timeframe does the crisis committee convene, and who informs the COBAC?
The subject has changed in nature across the sub region. The build up of the Central African Deposit Guarantee Fund, tighter capital requirements and consolidated supervision of regional banking groups have shifted the exercise from a documentary register to an operational one. A recurring confusion needs clearing up: the preventive recovery plan belongs to the institution, the resolution plan belongs to the authority. Conflating the two produces a hybrid document that serves neither purpose.
A compliance review ends with a binary answer: the plan has been submitted, it contains the expected sections, or it does not. The maturity assessment asks a different question: at what level of control does each component of the arrangements sit, and what specific action moves it up a level. A plan that is complete on paper can still be low maturity if no option has ever been simulated and no crisis exercise has involved senior management.
The framework is ready to use in Datamensio. It adapts to your institution: a subsidiary of a regional group, a nationwide retail bank, a smaller institution subject to proportionate expectations. The AI adjusts the themes, questions and levels, or builds a tailored version from your own documents, existing recovery plan, crisis management procedures, risk committee minutes.
Reference standard: CEMAC Regulation on the treatment of credit institutions in difficulty and banking resolution
The themes assessed
Governance of the recovery arrangements
Board approval of the plan, roles of the risk committee and senior management, designation of owners, update frequency, alignment with internal control.
Description of the institution and critical functions
Mapping of activities, identification of critical functions and core business lines, internal interdependencies, dependencies on service providers and market infrastructures.
Trigger indicators and thresholds
Solvency, liquidity, profitability and asset quality indicators, threshold calibration, calculation frequency, consistency with risk appetite and the management dashboard.
Recovery options
Rebuilding capital, mobilising liquidity, disposal of assets or business lines, cost reduction, impact costing, implementation timeline and identified obstacles.
Stress scenarios and testing
Idiosyncratic and systemic scenarios, severity retained, speed of onset, projection of indicators under scenario, testing the effectiveness of the options.
Escalation and crisis management
Procedure for identifying a threshold breach, timeframe for convening the crisis committee, decision chain, mobilisation of teams, simulation exercises and lessons learnt.
Communication and notifying the authority
Notifying the COBAC and the BEAC, internal communication, communication to depositors and counterparties, coordination with the Deposit Guarantee Fund.
Information systems and data quality
Ability to produce resolution data within deadlines, granularity on covered deposits, traceability of positions, reliability of reporting under degraded conditions.
Early intervention measures and follow up
Preparedness for measures the authority may take, tracking of commitments made, corrective action plan, alignment with follow up from inspection missions.
Group dimension and consolidated supervision
Consistency between the local plan and the group plan, intragroup support and its legal limits, transfers of capital and liquidity, coordination between supervisors.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does this assessment amount to COBAC approval of the recovery plan?
No. Only the supervisory authority rules on the plan submitted. The assessment measures the maturity of the arrangements, documents the gaps and produces the action plan to address them. It prepares for the review, it does not replace it.
What is the difference between a maturity assessment and a compliance check?
A compliance check verifies the presence of the required sections and concludes with a gap or a pass. The assessment places each component on a progressive scale and indicates the action that moves it up a level. A plan that is complete on paper can still come out at a low level if no option has been tested.
What is the distinction between a recovery plan and a resolution plan?
The preventive recovery plan is prepared by the institution and describes what it would do to recover using its own resources. The resolution plan is drawn up by the authority and organises the handling of a failing institution. The framework covers the former and assesses the capacity to feed data into the latter.
How long does the assessment take?
The short version takes 20 to 30 minutes to complete for a risk or compliance officer. The full version, run collaboratively, typically spans one to two weeks: most of the time goes into gathering input from finance, ALM, information systems and the general secretariat.
Can the framework be adapted to the size of the institution?
Yes. Questions, levels and themes can be modified, and you can add your own. The AI also builds a tailored version from your documents, which allows a proportionate expectation to be applied to a smaller institution without rewriting the grid.
Can several subsidiaries in the zone be compared?
Yes. The assessment can be rolled out across several entities, with a score by theme and a comparison between business units, as well as against previous assessments. The AI consolidates the gaps into a single roadmap at group level.
How does this assessment fit with other COBAC prudential requirements?
The recovery plan draws on the same data as solvency, liquidity and the ICAAP. A solid assessment provides a reusable foundation. The cross cutting roadmap allows several frameworks to be combined without duplicating actions.
Where is the data hosted?
In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.