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Risk & Regulation Round-up May to July 2018

This is the latest edition of my quarterly round-up of key announcements and developments in UK financial risk and regulation. Although it’s longer than usual the reporting in this edition is still quite summarised, and includes curated links to underlying source stories or documents for the reader who wants more detail.

The rubber is now hitting the road with regard to Brexit and its impact on financial services. Opinion is starting to coalesce around the possible (or even likely) outcome. Accordingly, this edition of the round-up includes an attempt to broadly summarise the position; though it remains complex and fast moving, with many variables.

This edition also includes some links to and coverage of technical communications relating to Brexit – notably from the Bank of England/PRA – which are starting to appear in preparation for the expected withdrawal in March next year.

Elsewhere the dizzying pace of policy and technical announcements from the likes of Basel, the FSB and the EBA continued. As did business as usual regulation from the EU, the PRA and the FCA.

To help readers see the wider picture, or pick up anything I don’t cover in detail, I include in this blog some comprehensive indices of publications and announcements from individual regulators’ websites.

*** Note: The articles in this blog do not constitute advice, but please contact me here for further information, including where to get the best advice. ***

Knowing Your Culture – The C Word In Financial Firms

Culture in financial services firms is – if not exactly a buzzword – more of a concern to regulators today than some of the themes that have historically preoccupied them.

Hardly surprising, given numerous failures of culture stretching back to the 1980s when governments across the world started deregulating markets: financial crises, bank collapses, huge losses, taxpayer bailouts, corporate and individual misdemeanours – many helped along the way by severe problems in the culture of the failing firms.

Iā€™m not going to use this blog to re-hash war stories that have already had ample publicity and coverage over the decades.

Instead I want to focus on what culture in financial services firms means, partly informed by my own experiences past and current. How do firms formulate and package their culture? Can the language that a firm uses in its external and internal communications provide any leading indicators of its culture?

Can stakeholders such as regulators, depositors, investors, employees and suppliers identify and recognise the underlying culture of a firm, in the absence of adverse – but lagging – indicators such as critical losses, collapse or regulatory failure? What signs or behaviours might be revealing of a shallow or expedient culture?

FRTB: Defining A Target Operating Model

The Fundamental Review of the Trading Book (FRTB) is still a long way away – January 2022 at the latest estimate. But the time will pass quickly. Banks with trading activities need to be planning towards it now or soon.

This blog is derived from a piece of work I did recently for a potential client. It suggests an approach to defining a Target Operating Model (TOM) for implementing the FRTB.

In truth this will be mainly of interest to banks which have not yet started their FRTB planning. For example subsidiaries, smaller banks, and banks with marginal trading activities but exceeding the de minimis exemptions.

Most large banks are well under way with FRTB implementation, and have been for some time, participating in industry groups, Basel Quantitative Impact Studies (QIS) and routine monitoring, getting buy-in from their business leaders, corporate program leaders and strategic IT planners.

But smaller banks, in my experience, are not. Understandably, they prefer to wait and see. There are no real advantages to being first movers in this initiative, which has already evolved far – though not beyond recognition – since 2012.

With so many uncertainties along the path, including Brexit and the strategic regulatory and policy intentions of the US Administration, being in mid-pack is a smart play.

Still, it is worth having a long-term think ahead about how you might eventually implement these rules if you haven’t already.

*** Note: This blog does not constitute advice, but please contact Prism-Clarity for further information, including where to get the best advice. ***


Risk & Regulation Round-up January to April 2018

This is the latest round-up in the series covering key announcements and developments in UK financial risk and regulation. I take my usual summarised and simplified approach to the main stories, but as always the regulators have been very busy.

A significant development for some of my clients and readers was the announcement by the Basel Committee of key changes to the Fundamental Review of the Trading Book (FRTB), the proposed revamp of the rules on market risk capitalisation of the trading book, which have been in development and consultation for some years: now due for implementation in 2022. See section 1.

Elsewhere, Fintech planning loomed large in the minds of regulatory and government agencies, especially but not only the European supervisory bodies. In similar vein but more broadly, Bank of England Governor Mark Carney made a thoughtful speech on the future of money in the light of the crypto-currency revolution. See section 2.

The topics mentioned here are just key highlights – see the detailed sections for more stories. See individual articles in this blog for links to underlying source stories or documents.

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