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The WannaCry cyber attack this month did not hit financial services (FS) firms as directly as it did some other industries, but its sheer scale across more than 150 countries and the level of disruption caused by the ransomware it deployed will force all businesses to re-examine their preparation for a major cyber event. In financial services, an industry characterised by the highest levels of interconnectivity, enhancing cyber resilience has been an urgently growing priority for firms and their boards.
A focus on vulnerability and competition: What firms can expect from FCA following the publication of its Mission and Business Plan 2017/18
On 18 April 2017, the Financial Conduct Authority (FCA) published several important documents, including its Mission, Business Plan 2017/18 and – for the first time – Sector Views. Together, these documents are intended to provide a complete picture of the way the FCA identifies and assesses risks, and hence identifies its regulatory priorities, in the sectors that it regulates.
Culture remains at the forefront of the global regulatory agenda: central bankers and supervisors set out their views
On 16 and 21 March, Andrew Bailey (Chief Executive of the Financial Conduct Authority), Mark Carney (the Governor of the Bank of England) and William C Dudley (President and Chief Executive of the Federal Reserve Bank of New York), gave speeches on improving culture in banking and financial services. The speeches together highlight the ways in which governance, remuneration and incentives drive the culture of a firm. They also provide a stocktake on regulatory initiatives intended to tackle these issues, and give insights into the areas that will attract particular scrutiny when supervisors assess a firm’s culture. The Governor also outlined a broad framework for addressing conflicts of interest.
The Prime Minister’s announcement of the Government’s decision to trigger Article 50 (Art 50) and commence the process of the UK’s formal withdrawal from the EU is momentous in many ways. However, for financial services firms - many of which have been working on their Brexit contingency planning for six months or more - the significance of today is that it means that they now have a maximum of two years in which to implement their plans.
The majority of large European banks have now released their 2016 Annual Financial Statements which included certain disclosures around IFRS 9 implementation.
The European Securities and Markets Authority (ESMA) has previously issued a public statement outlining its expectations of preparers of financial statements in the lead-up to the implementation of IFRS 9.
2017 Bank of England banking sector stress test exploratory scenario – Profitability in the spotlight
On 27 March the Bank of England (BoE) will publish the scenarios for its 2017 banking sector stress testing exercise. For the first time, the exercise will include an ‘exploratory’ scenario. Run in alternate years alongside the now familiar annual cyclical scenario (ACS), the exploratory scenario will enable the BoE to test the resilience of the banking system to a wider range of threats.
The introduction of IFRS 9 from 1 January 2018 will have a significant effect on regulatory capital across the banking industry, with four-fifths of EU banks expecting their stock of impairments to rise under the new rules according to a Deloitte survey. The European Banking Authority’s (EBA) estimates for the increase of impairment stock (provisions), compared to the current levels under IAS 39, is 18% on average and up to 30% for some firms. This led to an estimated decrease in Common Equity Tier 1 (CET1) and total capital ratios by an average of 59 bps and 45 bps, respectively. As a result, finding a mechanism to smooth any unwanted impacts following the IFRS 9 adoption, by avoiding a capital cliff-effect on day one, has rapidly become a priority for prudential regulators.
On March 9, Emma Dunkley wrote in the Financial Times about the new app-based banks aiming to steal a march on the incumbents. In her words:
“They are not expected to take a significant share of the market from the biggest banks.”
The implementation of the mandatory exchange of initial and variation margin for non-cleared OTC derivative trades in the EU commenced on 4 February for financial counterparties with the largest derivatives portfolios. The introduction of these rules – which was part of the G20’s mandate to reduce the systemic risk posed by the OTC derivatives trading – is expected to lead to an increase in the cost of trading for non-cleared trades.