BOEPrism

Risk & Regulation Round-up: September to November 2016

A quarterly round-up of key announcements and developments in UK financial risk and regulation: covering 1st September to 30th November 2016.

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

After covering Brexit in some depth in the last round-up, this time we include only a short section on Brexit, simply noting a few key publications and developments relevant to financial services.

Instead in this edition we focus more on routine technical and policy announcements from the EU/EBA, Basel/FSB and UK national regulators; including an important set of banking reform proposals from the European Commission issued on 23rd November.

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

Flesh of my Flesch: Readability Matters

This blog explores the concept of readability.

It looks at some common readability metrics – notably Flesch Reading Ease, Flesch-Kincaid and a couple of others – and wonders why as writing and editing professionals we don’t make more use of them, to promote our skills and measure our own performance in an objective way.

The metrics are now widely available in Search Engine Optimisation (SEO) tools and word processing software – including Microsoft WORD.

There are whole websites devoted to readability, with free tools to check your own content in lots of different ways.

The tools themselves are objective, intuitive and easy to understand. And they function well for relative comparisons – across multiple authors or over time – even if you can argue about their absolute value.

We already use them at Prism-Clarity to assess our own blogs and try to make them more readable. The argument now is to try using them for other purposes, and to get more people tuned in to them.

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.