EMEA Centre for Regulatory Strategy in Financial Services UK

The SSM six months on | How banks are getting on and what lies ahead

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The start of May marked six months of operation for the Single Supervisory Mechanism (SSM), the new framework for banking supervision in the Eurozone. The largest banks in the SSM have had their first taste of ECB-led supervision. The learning curve for them - and for supervisors at the ECB and national authorities - has been steep. And just as banks grapple with the task of responding to the new regime, the ECB has started tackling its supervisory priorities for 2015.

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Posted on 15/05/2015 | 0 Comments

Management information for conduct risk: Underpinning better decision-making

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Regulators are placing increasing emphasis on the management of conduct risk within financial services firms. Central to this is the right management information (MI). The importance of MI is also set to increase in the UK under the Senior Managers Regime (SMR) and Senior Insurance Managers Regime (SIMR), where strong conduct risk MI will help Senior Managers to demonstrate that they have taken reasonable steps to understand conduct risks and that they have put in place appropriate controls.

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Posted on 29/04/2015 | 0 Comments

Bank of England 2015 Concurrent Stress Testing Exercise | Scenario & Methodology

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The Bank of England has published details of its 2015 stress testing exercise for the largest UK banks and building societies, its second concurrent exercise (the first was in 2014).

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Posted on 1/04/2015 | 0 Comments

The FCA’s Coverholder and TPA thematic review | Due Diligence, Audits and MI

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This is the third of a four-part blog series on the FCA’s Coverholder and TPA thematic review (often referred to by the FCA as its “distribution chain” thematic review).

There has been a fundamental shift in regulatory expectation and good market practice for delegated authority control and oversight frameworks.

This shift may increase cost in key control functions reinforcing the importance of a robust conduct risk assessment (as discussed in our previous blog) to achieve a proportionate and risk-based control and oversight framework. The risk assessment shows you the higher gross risk areas of your business and why they are high risk, enabling you to direct your resource – whether it be delegated underwriting management, compliance, claims or underwriting resource - so that you get more bang for your buck. 

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Posted on 30/03/2015 | 0 Comments

EBA critiques critical functions in recovery plans

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The Bank Recovery and Resolution Directive (BRRD), a core piece of post-crisis regulation aimed at ending ‘too big to fail’, is being implemented across the EU. As part of the journey towards full and consistent implementation, the European Banking Authority (EBA) recently published a comparative analysis of the recovery plans of 27 (unnamed) European cross-border banking groups which collectively account for around half of the banking assets in the EU.

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Posted on 27/03/2015 | 0 Comments

EBA guidelines on limits on exposures to shadow banking entities

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On 19th March the European Banking Authority (EBA) issued a consultation paper which sets out its approach to limiting exposures from banks to the shadow banking sector, proposing that the large exposures regime be used to restrict exposures, in addition to existing Pillar II requirements.

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Posted on 26/03/2015 | 0 Comments

FCA Business Plan ǀ What firms can expect from the FCA in 2015-16

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Yesterday, the Financial Conduct Authority (FCA) published its Business Plan. Firms should read this document closely, as it outlines the FCA’s view on the key risks to its objectives, its priorities, and the activities it intends to undertake in 2015-16. 

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Posted on 25/03/2015 | 0 Comments

Senior Managers Regime ǀ Top Five Lessons Learned

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Her Majesty’s Treasury announced on 3 March 2015 that the commencement date for the Senior Managers Regime (“SMR”) will be 7 March 2016, and the Financial Conduct Authority (“FCA”) published its feedback statement on accountability on 16 March 2016. The timeline for commencement of the new regime is set; banks will have until 8 February 2016 to notify the Prudential Regulation Authority (“PRA”) and FCA of the names of all those, including people currently approved, who will be senior managers under SMR.

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Posted on 17/03/2015 | 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

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

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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