FRTB Programme: Focus On Documentation

Most firms with a Trading Book are now pressing ahead with implementing the new Basel Market Risk Rules – still widely known as the Fundamental Review of the Trading Book (FRTB) – and the documentation that goes with it.

But some smaller or medium-sized firms might not have really started yet. Nor might overseas subsidiaries. Or other firms who’ve been outside the scope of Basel’s intensive – and challenging – Quantitative Impact Studies (QIS) in the last three years.

Such firms will soon be planning their implementation. Or need to be. This blog looks to help, by focusing on the references to documentation in the new rules.

At Prism-Clarity we believe in the power of good documentation to highlight wider issues. We don’t believe in doing the documentation piece of a programme as an afterthought, a side-project or an inconvenience. It is and should be central.

By focusing early on the documentary outputs needed under the new rules, you can identify issues, ask good questions about your business, risk, other controls and technology, avoid false paths and potentially save costs.

Work backwards from the documentation to help shape your wider FRTB programme, or verify that your programme is on the right track.

A Short Dash To Oblivion: 16 Tips On Hyphens and Dashes

In a previous blog we rediscovered the joys of the semicolon; in this one we look at hyphens and dashes.

Not with the same enthusiasm, admittedly. We love the semicolon, but we’re more suspicious of the hyphen and wouldn’t use it if we didn’t have to.

As writers, editors and proofreaders the hyphen causes us angst. The rules are, at best, complicated. And hang the rules, usage is complicated too.

There is a generational split: older users prefer it, younger users demur.

Ideally we’d avoid using it. But we also want to avoid punctuational ‘dad dancing’, getting down with the kids and embarrassing ourselves.

So, deferring to our actual generation, we point out where you really can’t get away without using a hyphen.

And throw in some dashes at the end.

Passporting: What It Is And Why It Matters

Passporting is top of the list of many UK financial firms’ concerns post-Brexit.

“Will we keep our passporting rights as part of any negotiated deal relating to single market access when the UK leaves the EU?”

What does this mean? Why is it such a problem if UK firms lose their rights to “passport” into Europe? What are the alternatives and why are they so unpalatable?

And what is a realistic scenario given the different “trade models” that are possible examples for the UK post-Brexit (Norway, Switzerland and others)?

This blog tries to shed some light on passporting and why these questions matter.

We also look briefly at different trade models and apply a new metric – the Prism-Clarity “Single Market Access Compatibility” (SMAC) score. This is a judgment-based measure of the extent to which passporting – or something like it – might be possible under different trade models.

BOEPrism

Risk & Regulation Round-up: June to August 2016

A quarterly round-up of key announcements and developments in UK financial risk and regulation: covering 1st June to 26th August 2016.

Links to underlying source stories or documents are contained within individual articles in this blog.

The British EU referendum (‘Brexit’) vote on 23rd June 2016 was the most significant political and economic event in the UK and Europe for many years. So inevitably this bulletin contains some Brexit coverage. We try to avoid speculative treatment and broader political comment, and instead just summarise key announcements and developments relating to risk and regulatory aspects of Brexit.

Against the background of Brexit, the regulators pushed on with their technical agenda in a number of areas during the period. This included MiFID, structural reform (ring-fencing) and various aspects of capital regulation. The new Head of the Financial Conduct Authority warned that Brexit would not give rise to a “bonfire” of existing regulations. In other words regulated firms should expect – at least in the short term – a continuation of existing and proposed supervisory practice irrespective of Brexit.

Still, three themes seem to predominate in the post-Brexit environment for financial services firms:
(1) There will be ongoing uncertainty over both timing and substance.
(2) It is likely there will be some impact on passporting rights, into and out of the remaining EU. This will be covered in a future Prism-Clarity blog.
(3) Firms now have to plan and prepare intensively for a range of uncertain scenarios, while continuing to maintain both BAU and already-known implementations.

The articles in this blog do not constitute advice, but please contact Prism-Clarity for further information, including where to get the best advice.