It’s now over three years since the FSA asked banks to implement funds transfer pricing. It was difficult to fault the regulator on its stance. After all why shouldn’t product pricing reflect the risks incurred?
However regulation is straight forward in theory but the difficulties start when it’s put into practise. In the case of transfer pricing this was rightly or wrongly compounded by the perception that FTP was predominantly a quantitative issue. For something with a lot of moving parts this can’t be true. (All good risk pricing embeds subjectivity into models – just ask an options trader).
Proportionality also came into question. How sophisticated were simple firms expected to be? Could complex businesses get away with a basic approach?
The results were a bit piecemeal, that’s history and we moved on. And it’s made me think.
Why did FTP become last year’s problem?
Probably because of QE.
In a world of cheap money FTP is the last thing you want to hear about (or do). The “carry trade” is on and pays very well. Just ask any punter.
However if you feel, like me, that all good things come to an end then it’s a sound idea ask yourself how you make money. Is it through mispricing risk?
Now we have seen the first signs of tapering it’s hardly surprising that regulators are starting to ask the same question. And where better to start than a re-assessment of the FTP?
In a simple way it helps answer their question “do you know what you are doing?”
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