UK regulators refine the scope of the Senior Managers Regime and clarify how the ‘Presumption of Responsibility’ will be applied

Senior Managers


The Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) have confirmed how the new Senior Managers Regime (SMR) and Senior Insurance Managers Regime (SIMR) will apply to Non-Executive Directors (NEDs) in banks and insurers respectively. This follows the responses received to the Consultation on Strengthening accountability in banking: a new regulatory framework for individuals –CP14/14 published in July 2014, which expressed concern about the proposed approach to NEDs under the SMR.

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Posted on 24/02/2015 | 0 Comments

PRA and FCA consult on measures designed to encourage and protect whistleblowers

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The PRA and FCA have published a joint consultation paper (CP) on a series of measures to formalise whistleblowing procedures in firms. The aim is to encourage employees to raise concerns and protect whistleblowers from victimisation. This initiative responds to the Parliamentary Commission on Banking Standards’ recommendation to put in place effective mechanisms to allow employees to raise concerns internally.

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Posted on 24/02/2015 | 0 Comments

FCA competition study may come to have far-reaching implications for investment and corporate banking

The Financial Conduct Authority (FCA) has announced that it will kick-off a market study looking at competition in investment and corporate banking services in spring 2015. This comes as part of its review into competition in the wholesale sector, published yesterday, and follows its call for inputs last July. The FCA has found that limited transparency over both price and quality may make it difficult for clients to assess the value for money of investment banking and corporate banking services, and that bundling and cross-selling of services may make it difficult for new or smaller firms to compete against the established investment banks and universal banks.

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Posted on 20/02/2015 | 0 Comments

Capital Markets Union: Positive First Steps


The European Commission has fired the starting gun on the Capital Markets Union (CMU), the flagship agenda to deliver a single market for capital, by publishing its widely trailed first green paper (GP). In December we set the scene for the rapidly evolving CMU agenda and, although the GP is wide ranging, it contains little new information. 

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Posted on 19/02/2015 | 0 Comments

Advisory & supplier frameworks

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This is the final entry in our series of three blogs which cover the topic of third party risk. In this article, we explore the design and implementation of frameworks which organisations are implementing in order to help them manage the third party risk. We highlight some of the stages and challenges of creating such a framework and the requirement to make it specific to your organisation in order for it to be successful.

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Posted on 5/02/2015 | 0 Comments

Proposed revisions to the standardised approach to credit risk | More risk sensitivity, more complexity


On 22 December, 2014 the Basel Committee on Banking Supervision (BCBS) published a consultation paper on “Revisions to the standardised approach for credit risk”(CRSA) (Footnote 1). The aim of the revised CRSA as proposed by the BCBS is to tackle weaknesses in the current approach, including:

• over-reliance on external credit ratings;

• lack of granularity and risk sensitivity;

• out-of-date calibration;

• lack of comparability across different banks and jurisdictions; and

• misalignment of treatment between the current CRSA and exposures risk weighted under the internal ratings based (IRB) approach.

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Posted on 4/02/2015 | 0 Comments

Asset encumbrance disclosures: Navigating the maze

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Despite the increasing scrutiny by regulators and market participants on banks’ asset encumbrance levels, these remain poorly understood. With the objective of increasing market transparency on this area, a number of initiatives have been developed by regulators and standard setters. These include the recommendations to enhance the risk disclosures by banks published by the Enhanced Disclosure Taskforce (EDTF) and requirements to publicise asset encumbrance information within Pillar 3 disclosures, in addition to existing accounting requirements in IFRS 7.

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Posted on 3/02/2015 | 0 Comments

Software Asset Management | The costs of mismanaging software

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This is the second in a series of three blogs which covers the topic of third party risk. Last time we looked at performing contract compliance inspections of the third parties that you engage with. But what about your organisations compliance with its contractual obligations to third parties? In this blog we explore the area of Software Asset Management (SAM) in more detail, the benefits of good SAM and considerations when building an internal SAM capability.

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Posted on 29/01/2015 | 0 Comments

Financial Services | Third Party Risk

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Third party risk is currently a ‘hot topic’ within the Financial Services sector and senior executives across many organisations in the industry are having discussions to agree strategies, procedures and policies to mitigate the risks posed by third parties. This short blog is the first in a series of three which cover the topic of third party risk. In this first blog, we explore the use of contract compliance inspections in order to obtain assurance over third parties as well as generating significant financial recoveries.

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Posted on 23/01/2015 | 0 Comments

The London Business Footprint | The insurance sector’s impact on London’s office footprint

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Deloitte Real Estate’s comprehensive study of office occupation over a ten year period from 2004-2014 shows that financial firms now occupy 31% of all office space across central London. This represents the largest share among eight business sectors which include legal, TMT (Technology, Media and Telecoms) and professional to name a few.

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Posted on 21/01/2015 | 0 Comments

MiFID II: Product governance and unbundling dealing commission

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We are now a step closer to understanding how the EU landscape for capital markets and investment services is set to change following the publication last month of a bumper package of MiFID II / MiFIR implementing measures by the European Securities and Markets Authority (ESMA). On 19 December 2014, ESMA published final technical advice to the EU Commission and two consultation papers on regulatory technical standards (RTS) and implementing technical standards (ITS) (part 1 covers ESMA’s commentary and part 2 sets out the draft technical standards).

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Posted on 16/01/2015 | 0 Comments