EMEA Centre for Regulatory Strategy in Financial Services UK

The FCA’s changes to overdrafts and high cost credit


The FCA recently published two Consultation Papers (CPs); CP18/42 which proposes changes to overdraft regulation; and CP18/43 which proposes changes to the regulation of various high cost credit products.

Attention has focussed, in particular, on the proposed changes to overdrafts, which would:

  • end the distinction between arranged and unarranged overdrafts;
  • stop firms charging fixed fees for overdrafts; and
  • require firms to apply APR pricing to their overdrafts.

This blog summarises the package of changes proposed in the two CPs and explores their potential implications for firms.

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Posted on 24/01/2019 | 0 Comments

The Bank of England and PRA’s Resolvability Assessment Framework: end-state resolvability in firms’ hands

Banner_ImageIn December, the Bank of England (the Bank) and Prudential Regulation Authority (PRA) consulted on the Resolvability Assessment Framework (RAF) for firms[1] in the UK.

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Posted on 23/01/2019 | 0 Comments

The regulatory outlook for 2019

RO19 EMEA cover image small

As we enter 2019, firms will naturally ask themselves what they should be doing to prepare for the year ahead. When it comes to the all-important subject of regulation, firms will want to know what issues and concerns are at the top of the regulatory agenda and how they can best respond. To help firms with these vital questions, Deloitte publishes its annual Financial Markets Regulatory Outlook. The Outlook’s perspective is deliberately strategic, both in analysing regulatory strategies and priorities and in considering the implications for firms’ strategies and business models.

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Posted on 07/01/2019 | 0 Comments

Equity release mortgages – the PRA softens the transition but not the end-point regime

Equity release mortgages

In our July blog on equity release mortgages we explored the PRA’s proposals in its Consultation Paper CP13/18 to tighten significantly its approach on equity release mortgages (ERMs). Specifically, the PRA proposed, unusually, to specify particular assumptions that it expects to underlie the calculation of the “effective value” used to assess whether firms are claiming undue Matching Adjustment (MA) benefit for ERMs backing annuities.

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Posted on 20/12/2018 | 0 Comments

Implementing the FRTB in the European Union


Data from the European Banking Authority (EBA) published this Autumn, assessing the potential impact of Basel III reforms on EU banks, underlined the importance of the EU’s forthcoming implementation of global regulatory standards on the capital banks must hold for certain activities. One of the most immediate issues, from the EU’s perspective, is addressing capital requirements for market risk through the implementation of the Fundamental Review of the Trading Book (FRTB). The impact of the FRTB is widely expected to be substantial, with the EBA’s assessment finding that it would require a 52% increase in Tier 1 capital held against market risks for the group of 38 large EU banks that were assessed.

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Posted on 06/12/2018 | 0 Comments

How to avoid the common pitfalls on MiFID II transaction reporting


Transaction reporting was a key focus in MiFID I. Twelve firms were fined a total of £33m by the Financial Conduct Authority (FCA) and further fines were levied across the EU.1 With the greatly expanded rules under MiFID II, there are even more pitfalls. Our survey of ten EU regulators revealed that six of these are currently undertaking or planning supervisory activities on MiFID II transaction reporting, the FCA among them.2

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Posted on 05/12/2018 | 0 Comments

Open Banking around the world: towards a cross-industry data sharing ecosystem


Europe might reasonably claim to be the 'cradle of Open Banking'[1] - after all, PSD2[2] and the UK's Open Banking Standard pioneered it. But, look around now, and open banking initiatives are popping up everywhere. It is not just a matter of replicating the European approach elsewhere. Jurisdictions are adopting their own approaches to Open Banking, reflecting their markets and policy objectives, and in some cases developing cross-industry approaches beyond financial services.

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Posted on 29/11/2018 | 0 Comments

The FCA takes aim at price discrimination in the general insurance market


The FCA has become increasingly concerned that firms’ use of cross-subsidies or price discrimination (also known as differential or dual pricing) may lead to unfair outcomes for certain groups of consumers who, as a result of these pricing practices, end up paying higher prices. The FCA’s scrutiny of these practices was explored in our recent paper, “Cross-subsidies in the crosshairs.”

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Posted on 27/11/2018 | 0 Comments

FCA sets out its approach to competition


As part of its commitment to providing more transparency around its activities and decision-making processes, the FCA has released its final Approach to Competition (the Approach) document.  

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Posted on 13/11/2018 | 0 Comments

Cyber risk red-team testing in the EU: the path towards international collaboration?

Cyber Risk

The European Central Bank (ECB) earlier this year launched the first cross-border framework for the standardisation and coordination of cyber defence testing for financial institutions. This could well provide a blueprint for the global standard that has hitherto been absent, benefiting cross-border firms and more generally improving the sector’s cyber resilience. In this blog, we explore the latest European developments and consider what they could mean in this regard. Different regimes are already emerging around the world, but establishing certain commonalities could form the basis of an international approach.

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Posted on 05/11/2018 | 0 Comments