Japan	U.S.A.	UK
The Prime Minister shall decides if the systemic risk exception is applied, after consulting with the Financial Crisis Management Council. The members of the Council are as follows. The Prime Minister (Chairman) The Chief Cabinet Secretary The Minister of Financial Services The Commissioner of the Financial Services Agency The Minister of Finance The Governor of the Bank of Japan	The following approvals are required to apply the systemic risk exception. 2/3 of the FDIC Board of Directors 2/3 of the Board of Governors of the Federal Reserve The Secretary of the Treasury after consulting with the President	Based upon the Memorandum of Understanding, the HM Treasury, the Financial Services Authority and the Bank of England shall take coordinated actions for crisis management. The HM Treasury has an authority to nationalize banks. The HM Treasury shall provide blanket guarantee of deposits, based upon the common law power.

Note:

In the UK, resolution scheme peculiar to banks was introduced as temporary legislation in February 2008 and the bank-related bills passed in February 2009 made it permanent. However, there is no such systemic risk exception in the UK as in Japan and the U.S.A. Statutory law comparable to the systemic risk exception in Japan and the U.S.A. is temporary nationalization. The conditions for temporary nationalization are ①when it is necessary to resolve or reduce risks that affect stability of financial systems, ②when it is necessary to preserve public interests because public funds are used for financial assistance. Temporary nationalization does not require special procedure. Financial assistance such as blanket guarantee and capital injection are also possible measures. They are in accordance with Common Law instead of statutory law.