The times they are a-changin’
Ring out the old, ring in the new
Death, transformation and rebirth: from failing bank to phoenix – a Framework for Resolution
Post-Brexit Immigration Policy: Reconciling Public Perceptions with Economic Evidence
Branch Authorisation – UK leading the way
Good intentions go awry
More green shoots!
UK Finance responds to Green Finance Taskforce Report
Conduct Risk and Culture Academy: a new Academy for a new dawn
All the leaves are brown
Is the grass getting greener?
Signposting the ring-fence
Sustainable finance – an idea coming of age?
The updating of Pillar 3 disclosure requirements
Managing a Model Risk
Welcome reprieve of the FCA Register
What does the end of the term funding scheme mean for risk?
Bank’s proposals point to stronger resolution regime – but some reservations remain
Pragmatic approach to oversight of EU banks paves way for Brexit progress
Comfort and joy in Basel this Christmas
Next steps for the senior managers and certification regime
Pillar 2: What’s next?
Basel: An update
A resilient banking sector
UK Finance is pleased to respond to the Bank of England’s consultation on its approach to resolution statements of policy and onshored Binding Technical Standards1, whilst taking into consideration the separate PRA/Bank of England CP 26/18 on the UK withdrawal from the EU: Changes to the PRA Rulebook and onshored Binding Technical Standards.
Our response is supportive of the very comprehensive work it and the Bank of England have undertaken and highlights a number of areas where further clarity or extended transition periods would be helpful.
UK Finance is pleased to respond to the PRA’s consultation on CP6/18 Consultation Paper on Credit risk: the definition of default.
UK Finance has responded to the European Banking Authority’s consultation on its proposed Guidelines on management of non-performing and forborne exposures.
We supported the development of the Guidelines (GLs), whilst observing that Non-Performing or Foreborne Exposures are not a significant issue for UK banks.
CP6/18 is of interest to a wide range of our members, both UK based and those from overseas accessing the City’s centre of excellence in export financing. It could also detrimentally impact the ability of our members to finance exports by British manufacturers by increasing the cost of credit protection.
UK Finance has responded to the Basel Committee’s consultation on updating the Pillar 3 disclosure framework. Whilst fully supporting the principle of comprehensive disclosure of key metrics to support increased understanding by investors of a bank’s risk profile we were concerned that some aspects of the proposals were too granular and are not aligned with European proposals which have been recently finalised.
UK Finance has responded to the PRA’s consultation on the use of models in stress testing. We were supportive of the PRA’s initiative which comes on the back of its observations of good practice during the annual concurrent stress testing exercises.
UK Finance responds to the PRA’s consultation paper 29/17: ‘International banks: the Prudential Regulation Authority’s approach to branch authorisation and supervision’, which proposes a pragmatic approach to enabling firms operating in the UK under an EEA passport to convert to a third-country branch.
UK Finance has responded to the EBA’s consultation on Interest Rate Risk in the Banking book (IRRBB). We confirmed our continued support of IRRBB remaining a Pillar 2 risk and that individual institutions will continue to use their internal models as the basis for capital assessments within their ICAAP.
We are pleased to be able to respond to the PRA’s consultation paper CP 19/17.
UK Finance would like the PRA to be more explicit that the scope for the application of the double leverage considerations is where the PRA is the group home supervisor and that where the PRA is the host supervisor there is no expectation for the UK sub-group to consider the risk of double leverage at the group level.
UK Finance has responded to the PRA’s consultation on proposed changes to its large exposures framework.
We supported the proposal to exempt internal MREL exposures from LE limits, but expressed concern that expectations in relation to ‘practical and legal impediments to the transfer of funds or the repayment of liabilities’ was super-equivalent to CRR Art 113 (6) and that this should be rectified by copying across the CRR text to the Supervisory Statement.
UK Finance has responded to the Bank of England’s consultation on proposed revisions to its statement of policy on MREL, to take account of the FSB’s recently released finalised Principles for Internal TLAC.
Global regulatory coordination has vastly improved since the last financial crisis, with enhanced processes for cross-border resolution of large banking groups and greater interaction, collaboration and information sharing between regulators.
Joint UK Finance and AFME response to the FCA’s consultation to extend the Senior Managers & Certification Regime to all FCA firms setting out our broad support of the proposals, but highlighting some areas requiring further consideration.
UK Finance welcomes the opportunity to provide views on the Exposure Draft on Draft amendments to Guidance on the Strategic Report, published in August, in light of the Regulations implementing the EU Non-Financial Reporting Directive.
UK Finance has responded to the PRA’s consultation paper CP13/17 on Liquidity Risk in Pillar 2 which proposes the introduction of a Cash Flow Mismatch Risk framework. Whilst supporting a framework for addressing this particular risk, which arises as banks borrow short and lend long, we raised concerns about the CP’s assumption that all non-maturing deposits flow out of the bank on day one of a stress.
UK Finance has responded to the PRA’s recent consultation on recovery planning . We supported the recognition that a proportionate approach for smaller banks is appropriate but asked for clarity on how ‘recovery capacity’ should be calculated and questioned whether the requirements duplicated exiting ICAAP and ILAAP processes.
UK Finance, through its previous entities, has a long history of working collaboratively with Her Majesty’s Revenue & Customs (HMRC) to support the development of policy and other initiatives to monitor and facilitate compliance with its tax regimes.