This article contributes to the comparative literatures on varieties of financial capitalism, economic nationalism and bank resolution with a focus on Spain and Italy's management of bank insolvency and resolution between 2008 and 2018. Both countries' alternative banks faced enormous challenges through prolonged economic decline and declining loan repayments, both turned to depositors to become investors in lieu of attracting arm's-length investors to inject capital, and both had strong connections with local political authorities that resisted bank reform. But Spanish banks were restructured successfully in accordance with EU law while local government ties complicated Italian resolutions. We explain this outcome through two factors: state strength buttressed by outside assistance from the European Stability Mechanism; and strong international marketization, which enhanced the drive to restructure quickly. Spain's decision to ask for loans from the European Stability Mechanism to help restructure its heavily marketized savings banks allowed it to finish reforms after 2012.

The transnational governance of bank resolution must be well-designed to provide credible solutions to financial crisis management. While at policy level, there is a broad consensus on best practice, the implementation stage often leaves something to be desired. Focusing on the implementation of the relevant Financial Stability Board (FSB) recommendations in the EU, this article explores this issue and proposes certain reforms. It argues for closer EU control and scrutiny over national decision-making without, however advocating a “one-size-fits-all” approach. Its main insight is that the promotion of transnational convergence need not come at the expense of the distinctive attentiveness of EU law to local conditions nor indeed involve a massive shake-up of the existing EU architecture. Its aim is to contribute to scholarly and public policy debates in this field in anticipation of the EU response to the final conclusions of the post-implementation evaluation of the FSB recommendations, which is currently in progress.