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.
We note that the proposals announced by the European Commission in the CRD V requiring holding companies (Article 21a) to be supervised will likely make much of the intentions highlighted in this consultation to become invalid. We query whether, given this, the PRA should wait to see the finalisation of the Risk Reduction Package before attempting to address any possible residual risk in this space.
Please read the full response via the link below.