UK Finance response to the PRA’s consultation ring-fenced bodies: managing risks from third country subsidiaries and branches

UK Finance responds to PRA’s consultation on Ring-fenced banks (RFBs) managing risks from third country subsidiaries and branches.

See our response to the related HMT consultation on Near term Ring-fencing reforms for unintended consequences of the HMT proposals.

In addition, we call out other unintended consequences from the PRA proposals, including:

  • the PRA’s proposals, would be a tightening of the current requirements relating to ancillary undertakings .
  • the aim of the HMT’s near-term reforms risk being undermined by PRA rules, for example, use resources or expertise currently housed in the NRFB to provide relevant products and services to customers
  • the RFB subsidiary in a foreign jurisdiction would not be able to enter into structures that may be considered dealing in investments as principal, rendering it unable to compete with other banks in that market.