Bob Wigley speech to UK Finance Summer Reception

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Ladies and gentlemen, I am Bob Wigley, Chairman of UK Finance, thank you for joining us this evening for our summer reception.

And welcome to the beautiful College Gardens - which apparently have been cultivated for some 900 years.  

12 months ago, when we were last here, I talked of the challenges we all faced as we approached the 29th March 2019.

While those challenges are still to be resolved, UK Finance has been busy on other important projects?

In March, our application for the UK to remain part of a key euro payments system - SEPA - was successful, avoiding potential cross-border payment disruption for millions of individuals and SMEs on both sides of the Channel.

And while this kind of detailed policy development doesn't hit the front pages, it means we will all still be able to make and receive payments in euros and hold bank accounts in euros in the hopefully unlikely event of a ?no deal? Brexit.

We worked this year with consumer groups and industry representatives to develop the Authorised Push Payment Scams Voluntary Code.

Launched last month, this Code represents a milestone in consumer protection - delivering the commitment from all the banks and payment service providers who have signed up, so far over 85 per cent of push payments are covered - a commitment to reimburse a customer if they are the victim of an authorised payment scam and they did everything expected of them under the Code.

Last October we launched our initiative with the Bank of England and the National Cyber Security Centre to establish the Financial Sector Cyber Collaboration Centre. Working closely with our members, its mission is to proactively identify, analyse, assess and coordinate activities to mitigate systemic risk and strengthen the resilience of the UK financial sector.  

Over the past year we have also worked hard to support our members? customers including some of the most vulnerable.

We established a commitment to support thousands of previously ineligible homeowners who are tied to mortgage reversion rates in switching products.

We launched a Code of Practice for industry to support victims of financial abuse so firms can improve how they identify those at risk and help them regain control of their money.

And earlier this month we unveiled a comprehensive package of work to help local communities identify and secure appropriate free access to cash, building on the Access to Cash Review.

We?ve helped small and medium-sized businesses prepare for Brexit, collaborating with a number of business groups to launch our ?Let's Talk Business? campaign, encouraging firms to think about the potential impact and opportunities our departure from the EU will bring to their customers and supply chains.

We have been supporting the work of the Dispute Resolution Service Implementation Steering Group which is taking forward the development of an alternative dispute resolution system for SMEs, following Simon Walker's independent review.

Meanwhile our specialist police unit - the Dedicated Card and Payment Crime Unit - has continued to tackle the organised criminal groups behind card fraud, last year preventing an estimated £94 million of fraud and securing 48 convictions.

And our Banking Protocol - a rapid scam response scheme between branch staff and law enforcement - has continued to protect many elderly and vulnerable customers, saving them from losing £38 million of their own money to fraudsters last year and leading to 231 arrests in 2018.

And throughout the year we have continued to produce ground-breaking research and data, the latest of which highlighted the varied approach that consumers are now taking to payments with the rise in mobile banking and contactless payment.

It has been an incredibly busy year - and I would like to pay tribute to our first-class CEO Stephen Jones and all our staff for their hard and professional work and also to thank many of you here this evening for helping us to achieve so much.

I am proud to chair an organisation which represents an industry which serves society in such a crucial way.

Our industry helps families buy their homes with over £1.1 trillion in owner occupier mortgage lending; we help people to save for the future securely; and we support vulnerable customers with almost 7.5 million basic bank accounts.

We are supporting business at record levels, providing £58 billion in gross lending to SMEs last year - in fact bank lending to SMEs has increased by some 30 per cent since 2008, compared to GDP growth of around 13 per cent  -  we deliver the trade finance needed to help exporters enter new markets and we operate the systems that enable firms to take and make billions of payments every year.

We generate jobs and growth across the UK, employing over 1.1 million people, two-thirds of whom are based outside London, and we contribute over £36 billion in tax to UK public finances every year.

We deliver world-leading innovation, giving consumers new ways to pay, save, invest and borrow in a way and time that best suits them.

Our industry is hugely competitive, with new digital and physical business models emerging across banking, payments, cards, platforms and wallets all leading to greater customer choice and different propositions.

And notwithstanding what is going on just over the road, I still believe we are justified in being positive about a bright future.

We have strong, natural advantages that make the UK a world-leading financial centre and which won't be affected by Brexit.

Our language and time zone?our strong professional services skills?

...our world-revered legal system and respected and strong regulatory framework?

?our asset management industry and advanced research sector...

?and our position as a must visit roadshow destination.

These are all reasons why this country remains a formidable attraction to both international businesses and the best talent.

But we don't take our position as a leading centre for finance and banking and for innovation and investment for granted for a second.

We have been working on a bold vision for an internationally and internally competitive UK financial services sector post Brexit and recently Stephen and I have been sharing it with Government.

I do not think it's unfair to say that since the financial crisis and particularly during the Brexit negotiations, our sector and services generally have seen nothing like the level of strategic support and attention from Government that has been granted to goods and to technology.

I believe it is now time for the Government to set out a positive national vision for the role of banking and finance as a critical enabler providing essential support for the UK economy as a whole.

Such a vision will need to include principles which will guide the UK's approach to financial regulation - delivering policies which seek to maintain and promote the UK as a global leader, whilst continuously focusing on the importance of financial stability.

As many previous governments have done at critical pivot points, it is now time to create a new, formal body, chaired by the Chancellor, including all the relevant regulators and departments and the Governor, working closely with the banking and finance industry to create and implement this vision.

Let me be clear for the avoidance of doubt, this is no call for a return to light regulation or a race to the bottom. Strong internationally respected regulation and high standards are central to a robust and competitive banking and finance industry. But a thriving financial services sector is a necessity for an economy to grow and succeed.

Right now, we are seeing a multitude of new regulatory interventions being delivered by multiple regulators with at best insufficient coordination and at worst conflict.

We believe this is so overwhelming that without better coordination it could threaten the operational resilience which our industry and, most importantly, our customers and the wider economy, rely on.

So the first thing this body needs to do is ensure that regulatory initiatives are formulated and implemented with what we call effective air-traffic control - prioritisation and orderly implementation.

The second thing this body needs to do is develop a regulatory approach which really promotes competition. If you truly want to move the needle on competition in UK banking, you need to spur on not just the challengers and fintechs but the mid-tier banks below the top 6. There is only one mid-tier institution in the UK with assets over £50 billion.

These mid-tier banks today carry a disproportionately high regulatory burden, in effect being subject to the same rules and processes as their larger competitors.

And some might say that the Dear CEO letters from the regulator to the 20 fastest growing financial service firms last week - reminding them to grow their controls in line with their business - illustrates an embedded anti-growth, anti-competition bias within the system.

A firm with £20 billion of assets is NOT a systemic risk to financial stability and should not be treated the same as HSBC from a systems and controls perspective, particularly since it is simultaneously denied the regulatory benefits of scale e.g. more favourable capital treatments.

So we urge a review of the regulatory requirements for the mid-tier and smaller banks with a view to creating proportionate regulation for smaller banks, similar to the system the US has. Differentiating the 'too big to fail? from the ?big enough to grow in a way which would meaningfully move the competitive needle?.

The third thing this new body would need to consider is whether the existing regulatory definition of banking and our regulatory system for banks appropriately captures the new and exciting business models emerging at unprecedented speed in bigtech.

I would argue that many of the bigtech companies are moving rapidly into banking and to market positions of dominance in particular niches which are not currently regulated as to conduct, prudential capital, data use or conflict of interest. Regulation 2.0 needs to be developed to deal with their business models.

With the loss of passporting on Brexit, we will need to find ways of making the UK internationally attractive if we are to retain and attract international banks here. That means recognising some of the structural disadvantages to locating a bank here we have allowed to develop over recent years.

Our recent tax report showed that the aggregate rate of tax paid by banks in NY would be 34 per cent, in Frankfurt 44 per cent and in London 51 per cent. This cannot be sustainable post Brexit without an even larger outflux of international banks than Brexit itself may deliver.

At the heart of the vision created by this new body must be a mantra that the UK will be the safest and most transparent place to conduct financial services business in the world. That is why we are working hard with the Chancellor and Home Secretary on a joint public private threat assessment and Economic Crime Strategy with clear prioritisation to address the most serious threats.

We are playing our part in building strong public-private partnerships to tackle illicit finance, cyber risk and fraud more generally.

We have suggested to government where to focus and what powers we need to be able to share data, information and intelligence on the latest threats - and to do so in real time - both within and across the public and private sector.

If the Government's challenge is to raise more tax without raising taxes, then introducing a national e-id or financial passport system and combining it with moves to a ?less cash? society would be the sure-fire way to attack the black economy and increase the fairness of the tax burden on different elements of society.

Ladies and Gentlemen, you have been very patient. I have tried to share with you the important initiatives we have worked hard on since we last met in these gardens.

I have explained how we see our highly competitive industry at the heart of a thriving economy serving the whole of society including the most vulnerable.

And I have been positive about the future - setting out a bold vision for a way forward - albeit one that requires some serious strategic planning and partnership between Government and industry and some bold political decisions.

With the continued collaboration of all of you - I believe our UK industry will absolutely continue being the envy of the world. Please support us in the journey and thank you for coming.

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