The bail-in rules, like all Community rules, were approved by the European Parliament. The Bank of Italy provided technical advice and voiced its opposition within the competent institutions. On the Bank’s website is a working paper that the Italian delegation submitted to the European Council on 12 March 2013, when negotiations for the directive were under way. This shows that Italy has always upheld that the bail-in should only apply to newly issued instruments, i.e. that it should not have ‘retroactive’ effects. It also called for a 3-year transition period (from 2016 to 2018) to allow banks to gradually build up the cushion of liabilities (the MREL) needed to absorb bail-in losses, to be offered to knowledgeable investors. Italy put forward these proposals repeatedly during the European negotiations but they were not incorporated in the directive.