—

annul the defendant’s decision of 14 April 2021 on the calculation of the ex-ante contributions to the single resolution fund for 2021 (ref: SRB/ES/2021/22) in so far as the decision concerns the applicant;

—

stay the present proceedings under Article 69(c) and (d) of the Rules of Procedure of the General Court until a final decision is issued in cases T-413/18, (1) T-481/19, (2) T-339/20 (3) and T-424/20 (4) und C-664/20 P (5) or until those cases are otherwise brought to a conclusion;

—

order the defendant to pay the costs of the proceedings.

1.

First plea, alleging infringement of Regulation (EU) No. 806/2014 of the European Parliament and of the Council of 15 July 2014, (6) Council Implementing Regulation (EU) 2015/81 (7) and TFEU through increases in the amounts of the contributions to be paid by the applicant to the Fund.

2.

Second plea, alleging infringement of Article 41(2)(c) of the Charter of Fundamental Rights of the European Union (‘the Charter’), on the ground that the calculation procedure does not allow for a complete statement of reasons for the contested decision. Delegated Regulation (EU) 2015/63 is partially ineffective.

3.

Third plea, alleging infringement of Articles 16 and 20 of the Charter, since, in view of the special situation of the applicant, the contested decision is at variance with the general principle of equality and infringes the principle of freedom to conduct a business.

4.

Fourth plea, alleging infringement of the essential formal requirements and possibly of Article 5(1) of Implementing Regulation (EU) 2015/81, as it is unclear whether the SRB Decision was authenticated. In addition, the defendant failed to clarify the situation sufficiently, did not grant the applicant a hearing before the adoption of the SRB decision and did not give sufficient reasons for its decision.

5.

Fifth plea, alleging, in the alternative, infringement of Article 69(1) of Regulation No 806/2014 due to an excessive target level, since the defendant may have set the target level at no more than EUR 55.000.000.000.

6.

Sixth plea, alleging, in the alternative, infringement of Article 70(2) of Regulation No 806/2014 in conjunction with Article 103(7) of Directive 2014/59/EU, since the defendant, in calculating the amount of the contribution, should have excluded risk-free liabilities from the relevant liabilities.

7.

Seventh plea, alleging, in the alternative, infringement of Article 70(6) of Regulation (EU) No 806/2014 in conjunction with Article 5(3) and (4) of Delegated Regulation (EU) 2015/63, since the defendant wrongly calculated the applicant’s contribution on the basis of a gross approach with regard to derivative contracts.

8.

Eighth plea, alleging, in the alternative, infringement of Article 70(6) of Regulation (EU) No 806/2014 in conjunction with Article 6(8)(a) of Delegated Regulation (EU) 2015/63, since the defendant wrongly regarded the applicant as an institution undergoing reorganisation.