Regulation

Related Documents

Living documents

16th July 2010

If you have read some of the UK regulator's policy then you may well have come across the term "living document". What does it mean?

Policy Statement 10/5

21st April 2010

Policy Statement 10/5 A specialist sourcebook for building societies: Enhanced supervisory guidance on financial and credit risk management. March 2010. The following refers to treasury management What's it about? This PS follows on from CP09/17. It's about how the FSA expects building societies to manage their treasury business. The resultant Building Societies Sourcebook (BSOCS) isn't too complicated but putting it all into practice may prove to be a challenge. A society is expected to align itself with one of five approaches used to define treasury risk management.

Regulation > Does liquidity risk overshadow market risk?

23rd January 2010

In a world where regulators are focusing on liquidity and capital it's easy to overlook market risk. In many firms this means interest rate exposure. In the UK with Bank Rate at an all time low it's tempting to think that hedging fixed rate assets is just a waste of money. After all why pay 3.25% on a 5 year swap when 3 month Libor is only 51 basis points? Surely matching the interest basis on assets and liabilities ends up costing you 274 bps doesn't it?

PS 10 5 presentation January 2010

15th January 2010

This presentation is about the introduction of new liquidity standards in the UK. It was delivered to bank and building society executives and NEDs in January 2010.

Regulation > Predicting the future just got easier

4th January 2010

Leafing through the pages of the Sunday Times late in December 2009 reminded me how dangerous predictions can be. Economic forecasts made a year earlier by leading institutions proved in many cases to be well off the mark. To be fair it's always been a mine field. But there is one area that I can safely predict in the coming year. That's regulation.

Regulation > Policy statement 09/20 Stress testing and scenario testing December 2009

18th December 2009

What's stress testing about? The regulator is imposing a stress testing regime on firms because the risk management techniques employed before the crisis did not accurately reflect what could happen. In particular risk models allowed firms (and regulators) to ignore tail-risks. As a result many firms have found themselves badly exposed in the crisis. In order to mitigate against this happening again the FSA is making stress testing and reverse stress testing mandatory. Let's answer a few questions.

Regulation > Liquid assets

14th November 2009

Two things took my eye in the FSA's Policy Statement 09/16 - Strengthening liquidity standards. I thought I might share them with you. The first altered my opinion, the second puzzled me.

Regulation > Policy Statement 09/16 Stengthening liquidity standards October 2009

7th November 2009

Policy Statement 09/16 Strengthening liquidity standards refers to earlier consultation papers CP08/22, CP09/13 and CP09/14 and the comments received. In general whilst the FSA acknowledges many of the issues raised little has altered in the final policy. Firms will be expected to be self sufficient for liquidity purposes. Senior management is responsible for reviewing the level of liquidity, compliance and reporting to the Board. The FSA highlights that many firms have been unable to identify and report contractual cash flows on a regular basis. This will be unacceptable. Non compliance will be treated with regulatory sanction. How a firm is subject to Individual Liquidity Adequacy Standards (ILAS) depends on the size of the firm and the risks it presents. The ILAS framework comprises an Individual Liquidity Adequacy Assessment (ILAA), a Supervisory Liquidity Review Process (SLRP) and Individual Liquidity Guidance (ILG). Firms are obliged in the ILAA to undertake robust stress testing. The purpose of this is to show that the firm fully understands its liquidity risk. ILAS firms will need to report the stress test results in their ILAA. Liquidity management systems, controls and stress testing are all board responsibilities. The ILG is the amount of liquid resources the FSA expects a firm to hold. This will contain "guidance" on the amount of the liquid asset buffer and the firm's funding profile. As an incentive for firms to improve their systems and controls, the FSA will increase the amount of liquidity the firm must hold. Deposits at the central bank and tradable securities issued by the central bank will count towards the buffer. Holding currency denominated bonds should take into account potential problems in the FX market. For this reason a domestic bank with mainly sterling liabilities must hold its buffer in gilts. The FSA now require firms to price the cost of liquidity into products. This should mean that the cost of holding the liquidity buffer is passed on to those customers that create a stressed outflow requirement. The new regime will be phased in. The scope and application of the new rules will depend on the importance of the firm and its ability to create systemic risk.

Regulation > Do liquid assets give you risk?

14th October 2009

This is written for anyone interested in liquidity. Here's a brief summary. Firms will be required to hold substantially more liquidity (20%); T-bills, cash and treasuries (Gilts) will be the main recipients; Gilts are not risk free; Interest rate risk can be hedged; Swap spread risk, (basis risk), can't and the risk can be large; Try the liquid asset KISS test; It's the balance sheet structure that will give you the edge (is that what individual assessments are about?)

Regulation > Consultation Paper 09/17: A Specialist Sourcebook for Building Societies June 2009

1st August 2009

The general thrust of the CP is that Societies must prove that they have both the management and the systems capable of effectively dealing with the risks they face. This is part of the enhanced supervisory approach now adopted by the FSA. It states that systems and controls must match the level of complexity in a firm's business model. The FSA will adopt a more interventionist approach in order to ensure this is the case. The proposal is that building societies and the regulator will determine whether the risk management policies adopted are appropriate. Where they are not the Society can either simplify its business or improve its risk management. The FSA also intends to limit societies diversifying their business without a full assessment of capital adequacy. The FSA has considered applying similar CP 17 guidance to the banking sector but has decided on account of the "lack of homogeneity" that this would not be practical and in their case a firm-by-firm approach is more appropriate. The CP addresses treasury and lending. It contains five approaches to treasury management, three areas of treasury guidance and three approaches to lending. Consultation closes on 5th September 2009 with implementation due in early 2010 when a new Building Societies Sourcebook (BSOCS) will replace IPRU-BSOC.

Regulation > CP 09/14 Strengthening liquidity standards 3: Liquidity transitional measures June 2009

29th June 2009

The FSA presumes that every firm must be self sufficient for liquidity purposes unless a waiver is granted. The systems and controls requirement applies to all firms from Q4 2009 and will have no phased or transitional introduction. This is a summary of the CP.

Regulation > CP 09/13 Strengthening liquidity standards 2: Liquidity reporting April 2009

28th April 2009

This CP is mainly concerned with questions about what firms should report and the frequency and scope of reporting. The Individual Liquidity Guidance (ILG) will lead to a strengthening of firms' liquidity over a period of several years. The rules and guidance on liquidity risk including the transitional arrangements are to be effective in Q4 2009. New reporting arrangements are to go live in Q1 2010.

Regulation > Consultation Paper 08/24 Stress and scenario testing December 2008

12th April 2009

The FSA wants to see more stress and scenario testing in firms. Senior management should be involved. Previous assumptions have been too relaxed. Stress testing should be in detail with the mitigating actions rehearsed. Reverse stress testing is introduced as a method of identifying critical events. The FSA is not going to tell you how to do this, it's up to you. However firms can expect greater challenge on the assumptions made.

Regulation > Consultation Paper 08/22 Strengthening liquidity standards December 2008

31st January 2009

This CP sets out the FSA's plans to reform the liquidity regime. It requires firms to undertake a much more rigorous analysis of their liquidity position. This includes the effect of stressed conditions on their business. The firm will submit what it considers to be an appropriate liquidity buffer to the regulator. The FSA will then decide whether it is sufficient. In determining the buffer the FSA will also assess the firm's systems and management. If these are considered weak the buffer will be increased accordingly. The liquidity buffer can only be held in liquid assets. The FSA's view is that this primarily means Gilts, sovereign debt or central bank deposits. The FSA makes it clear, "The responsibility of adopting a sound approach to liquidity risk management is on firms and their senior management".