Banking in Financial Services UK
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2016 has been another difficult year for the financial sector, with economic and political uncertainty complicating the completion of the post-crisis regulatory repair agenda.
Three years on from CRD IV/CRR being finalised, the EU’s banking sector now faces a revised Capital Requirements Directive and Capital Requirements Regulation (CRD V and CRR II), and a host of other legislative amendments, in a 500+ page package published today. These revisions to CRD V/CRR II and amendments to the Bank Recovery and Resolution Directive (BRRD) are likely to stretch significant regulatory change into the next decade.
European Commission proposes 12 month PRIIPs Delay, but uncertainty around timing of the legislation means firms should maintain momentum
On 9 November, the European Commission published a legislative proposal to extend the application date of the Packaged Retail and Insurance-based Investment Products Regulation (PRIIPs) by one year. PRIIPs requires the disclosure of Key Information Documents (KIDs) when PRIIPs are sold to retail investors. The delay has been widely anticipated by the market and gives manufacturers and distributors of PRIIPs products until 1 January 2018 to put implementation plans in place. The Commission did not amend any other provisions in the Level 1 text. The proposal follows a vote by the EU Parliament on 14 September to reject the EU Commission’s Regulatory Technical Standards (RTS) on PRIIPs and concerns expressed by 24 Member States in the Council in a vote by the Competitiveness Council of the EU on 20 September (see our blog of 20 September for further detail on the Parliament’s rejection of the RTS).
Assurance over bank regulatory capital | ICAEW proposes framework to support confidence in banking regulatory ratios
The ICAEW on Tuesday published its exposure draft of a technical release “Banking regulatory ratios: ICAEW assurance framework”, which proposes a flexible and modular framework for both internal and external assurance on banking regulatory ratios.
There has been no shortage of deeply damaging scandals affecting the financial services sector in recent years, all of which can be linked to governance and cultural failings. Andrew Bailey, who recently moved from CEO of PRA to lead the FCA, has on numerous occasions spoken on the importance of corporate culture and has stressed that “the culture of firms…is of the utmost importance to regulatorsi”.
In 2017 the Bank of England (BoE) will introduce the biennial exploratory scenario (BES) as part of its annual concurrent stress test of UK banks. Outlined as part of the BoE’s 2015 update to its stress testing approach, the BES complements the annual cyclical scenario (ACS), enabling the BoE to assess firms’ resilience to a wider range of threats. The BES will be designed to delve into the more complex aspects of a firm’s risk profile, in the process testing not just its resilience, but also its capacity to model and manage risk.
On 6 October 2016, the European Banking Authority (EBA) launched a consultation on its draft “Guidelines on Information and Communication Technology (ICT) Risk Assessment” (the Guidelines) under the Supervisory Review and Evaluation Process (SREP). The consultation runs until 6 January 2017.
Swings and roundabouts
The long-term success of the marketplace lending model in the UK will depend on how enduring its competitive advantages are, and how well marketplace lenders (MPLs) mitigate risks. In this blog, we explore some of the principal sources of competitive advantages for MPLs in the UK, and also some of the strongest headwinds facing them.