Investors in bonds issued by European banks are facing a confusing patchwork of new national bank resolution regimes, under which bank bondholders will face very different treatments in different jurisdictions.

Ireland is preparing a national resolution regime, to be introduced by the end of the year, which the market expects will follow the model of the Anglo Irish Bank restructuring. This protected senior bank bondholders, while imposing losses on junior bank bondholders of 80 cents on the euro.