Capital Markets in Financial Services UK
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Senior Managers and Certification Regime | Changes to Functions, Responsibilities and Scope of Conduct Rules
On 28 September, the Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) issued a suite of publications setting out a number of proposed amendments and optimisations to the Senior Managers and Certification Regime (SMCR) for banking firms. In addition to providing feedback on firms’ grandfathering submissions they introduce a number of changes which will impact existing Senior Manager Function holders (SMFs).
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.
Deloitte’s report “Marketplace lending – a temporary phenomenon?” explores whether marketplace lenders (MPLs) represent a truly disruptive threat to the UK banking industry. As part of our research, we commissioned YouGov to carry out a survey of individuals and small and medium-sized enterprises (SMEs) to find out more about the awareness, usage and growth potential of marketplace lending in the UK.I
Firms subject to Senior Managers and Certification Regimes (SMCR) are obligated to capture, assess, and report breaches of Conduct Rules by individuals who are in scope of the rules. Holding individuals to account is a core concept of the new regime.
A perfect storm
In the wake of the global financial crisis, UK banks pulled back from lending, owing to higher regulatory capital requirements and greater regulatory and shareholder scrutiny of their business models. They have adopted more risk-averse lending strategies in this environment, with more stringent reviews of the creditworthiness of borrowers.
In recent papers1, the Basel Committee (BCBS) has proposed a number of changes to the scope and use of internal modelled approaches. Taken together, they represent a tectonic shift in banks’ ability to use internal models for regulatory capital purposes:
Cooling the buy-to-let spending spree | PRA proposes higher standards and capital charges for buy-to-let mortgage lending
The PRA published a Consultation Paper and draft Supervisory Statement on 29 March on more strict standards for buy-to-let lending. The proposals coincided with the FPC’s statement on macroprudential risks on the same day, which included concerns about the buy-to-let property market.
The FCA published its 2016-17 Business Plan on 5 April. The document is shorter and less detailed than in previous years, with only a brief Risk Outlook section, and makes limited announcements of new work. This may reflect the fact that the new CEO, Andrew Bailey, will not join the FCA until July, although as a member of the FCA Board, he will already have had an opportunity to influence the Plan. Like last year, the FCA has continued with its magic number of seven priority areas, rolling over five areas and prioritising two new areas – wholesale markets and the provision of advice.
The Senior Managers and Certification Regimes (“SMR”) and new Conduct Rule requirements are high on the agenda for many of our clients’ Audit Committees following their landing earlier this year. The changes, impacting banks, building societies, credit unions and designated investment firms, are designed to improve professional standards and culture. They have led to a flurry of activity across the sector in changing and implementing policies and processes to enable compliance.