Key considerations on institutions’ credit IRB and IFRS 9 models
Mazars provides an update on recent developments affecting financial institutions’ credit capital and provision models with focus on the EBA IRB Roadmap and COVID-19 relief measures.
Before the onset of the COVID-19 global pandemic, regulatory bodies across the Eurozone published guidance to financial institutions as part of the European Banking Authority’s (EBA) Basel III implementation roadmap. One key objective is to reduce non-risk-based variability in Risk Weighted Assets (RWA) through harmonisation of capital approaches. The guidance covered a range of topics including the revised definition of default and estimation techniques on Probability of Default (PD) and Loss Given Default (LGD)[1] for calculating RWA, to name a few.
Since 2016, the ECB in conjunction with local regulators and industry experts, conducted Targeted Review of Internal Models (TRIM) for important financial institutions’ retail and non-retail portfolios. Institutions were provided with deadlines to implement remedial actions arising from these onsite inspections and model reviews in the lead up to the implementation of Basel III.
Additionally, the revised definition of default considers Specific Credit Risk Adjustments (SCRA), which references Stage 3 assignment under IFRS 9 for default identification and requires existing information, without undue cost and effort, to be used for estimating provisions. As such, accounting guidance in response to COVID-19 is highly relevant to ensure consistency in the default identification between capital and provisioning.
The below section outlines some of these relief measures that government and local regulators have put in place for institutions concerning default identification and IFRS 9 provisioning processes.
Non-performing loans (NPLs) are exposures that defaulted, either through missed payments and/or unlikely to pay triggers. NPLs are assigned higher capital and provisions driven by 100% PD. The EBA’s 2017 Quantitative Impact Study (QIS) showed high variances in the definition of default where it appears that a quarter of respondents were not using probation periods and over a third had automatic UTP triggering (i.e. not case-by-case assessments), among other variances. It is clear from publications by the BCBS and local regulators that COVID-19 relief measures[2] [3] [4] must be considered by financial institutions in their risk estimation procedures. Some examples are:
These present considerable operational efforts by institutions in addition to the planned transitional arrangements prior to the announcement of relief measures. Furthermore, with social distancing, work from home and employee furloughing, institutions face high resourcing constraints.
Although the accounting standards and their implementation does not fall within the remit of the ECB banking supervision, the ECB published guidance[6] to mitigate volatility in regulatory capital and financial statements to avoid “excessively procyclical assumptions” in expected credit loss (ECL) estimation as these rely on macro-economic forecasts. Some key considerations are shown below:
The IFRS 9 standard requires ECL to be estimated on an unbiased probability-weighted basis using reasonable and supportable information that is available without undue cost or effort. These principles can still be applied, as per the published guidance[7] , during periods of uncertainty without requiring model re-developments, but may require re-prioritisation of efforts to ensure a smoother transition. An example is that overlays are used for 2020Q1 followed by model updates (including scenarios) from 2020Q2, although these depend on individual circumstances of each institution, and the local regulatory expectations.
To alleviate operational burdens facing institutions, the EBA and local regulators extended timelines so that institutions can prioritise efforts towards customer support and their core business.
The UK’s Prudential Regulatory Authority (PRA) proposed an accelerated deadline of 2020 for residential mortgage IRB models to coincide with their implementation timeline of the hybrid PD approach[10] . With the above extensions, it is possible these timelines may be revisited.
Regarding IFRS 9, institutions are racing against the clock to incorporate relief measures and economic projections for their 2020Q1 reporting when the extent of such risk mitigating measures are still unknown, especially given lags in default identification and reporting. Under tight deadlines and resourcing constraints, it is anticipated that institutions will rely heavily on post-model adjustments / overlays based on a combination of judgement and industry analysis to determine where such overlays should be applied and prioritise efforts towards reporting disclosures to show COVID-19 impacts for greater transparency across the financial sector.
As the global pandemic unfolds, institutions and regulatory authorities are introducing unprecedented measures to alleviate financial and economic impacts. These measures present considerable operational burdens for institutions to implement, in addition to existing regulatory requirements, during periods of high resourcing constraints. Institutions should ensure their systems and procedures are flexible enough to incorporate relief measures and judgement (including economic forecasting) are incorporated using reasonable and supportable information without customer detriment. Additionally, considerations for alignment across the industry and models (IRB – IFRS 9) should be integrated so that the overall objective of harmonisation can be achieved.
Sources
[1] https://eba.europa.eu/regulation-and-policy/model-validation/guidelines-on-pd-lgd-estimation-and-treatment-of-defaulted-assets
[2] https://www.bis.org/bcbs/publ/d498.pdf
[3] https://www.bankingsupervision.europa.eu/press/pr/date/2020/html/ssm.pr200320_FAQs~a4ac38e3ef.en.html
[4] https://eba.europa.eu/sites/default/documents/files/document_library/News and Press/PressRoom/PressReleases/2020/
[5] https://www.fca.org.uk/firms/mortgages-coronavirus-guidance-firms
[6] https://www.bankingsupervision.europa.eu/press/letterstobanks/shared/pdf/2020/ssm.2020_letter_IFRS_9_in_the_context_of_the_coronavirus_COVID-19_pandemic.en.pdf
[7] https://cdn.ifrs.org/-/media/feature/supporting-implementation/ifrs-9/ifrs-9-ecl-and-coronavirus.pdf?la=en
[8] https://www.bankofengland.co.uk/news/2020/march/boe-announces-supervisory-and-prudential-policy-measures-to-address-the-challenges-of-covid-19
[9] https://www.bis.org/press/p200327.htm
[10] https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/consultation-paper/2019/cp2119
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Central Bank Digital Currencies (CBDCs) continue to receive increasing attention not only from the ECB but all over the world. So far, 10 countries [1] have already deployed CBDC programmes with another 15 countries [2] currently conducting pilot programmes. In total, 105 countries are considering using CBDC programmes, representing over 95% of global GDP and […]
The chair of the European Central Bank’s Supervisory Board, Andrea Enria, has voiced several times in the past months the supervisor’s concern with the increasing growth of the leveraged finance sector, which deals with loans to highly indebted borrowers. By mid-2021, the combination of a strong global loan moratoria policy and the long-standing low interest […]
The war in Ukraine, as well as the unprecedented sanctions imposed by the European Union, the United States and their partners against Russia have had major consequences for financial services institutions. For foreign companies operating in Russia or Ukraine, the first concern was the safety of their staff. They had to make difficult choices to […]
While the European Commission’s most recent opinion on the review of the Solvency II Directive is broadly in line with the final European Insurance and Occupational Pensions Authority (EIPOA) opinion issued in December 2020, some measures have now been amended. These amendments are designed to strengthen the capacity of European insurers to contribute to the […]
Regardless of geography or business sector, many groups and companies have taken out cybersecurity insurance policies in recent years. These policies cover companies against new threats to information systems, including ransomware and data theft incidents that have been making the headlines. For a long time, the risks identified in these policies were on the borderline […]
The European Green Deal aims to achieve climate neutrality by 2050 and create a modern, competitive and resource-efficient economy. To meet its objectives, the European Commission has begun to restructure the non-financial reporting requirements for companies. Although some of the requirements were partially implemented in 2021, this is only the beginning of a real sea […]
Since the European crisis management framework was established in 2014, there have not been many failing banks in Europe. However, the recent global health pandemic, combined with the ongoing conflict in Europe between Russia and Ukraine, could easily change this. The EU crisis management framework was established in response to the global financial crisis and […]
Crypto-asset markets have been on banks’ radar for some time. While interest and involvement have varied, regulatory developments have been a driving force. In September 2020, the European Union (EU) published a proposal for the regulation of Markets in Crypto-assets (MiCA), offering a uniform legal framework for crypto-assets in the EU. On 14 March 2022, […]
As a setting for exchange between European Union (EU) economic and financial regulators and senior financial sector executives from the industry, one of the world’s largest financial services conferences, Eurofi, took place in Paris in February. Established in 2000, the Eurofi meetings occur bi-annually* alongside the Economic and Financial Affairs Council configuration (ECOFIN) meetings. The […]
In March 2022, the European Central Bank (ECB) published its second snapshot of climate-related and environmental risk disclosure levels among significant institutions under its direct supervision. In line with the results of the first snapshot published in November 2020 – regarded as the baseline measurement – none of the institutions in scope for this second […]
The invasion of Ukraine by Russia on 24 February 2022 is considered the most significant geopolitical event since the Second World War. While there is no question of military intervention by the European Union (EU) at the moment, the EU has nevertheless decided on a major package of sanctions that will have a heavy impact […]
A central database to strengthen the anti-money laundering and counter-terrorist financing (AML/CFT) framework was launched by the European Banking Authority (EBA) on 31 January 2022. Called EuReCA, the new database will be essential to coordinate efforts by national competent authorities and the EBA to prevent and fight money laundering and terrorist financing (ML/TF) risks throughout […]
Like all industries, the real estate sector has to implement a range of legal, technical and organisational measures to protect the personal data of its employees, customers, prospects and suppliers. Processing must comply with several regulations related to data protection, including, for example, the General Data Protection Regulation (GDPR), applicable since 25 May 2018. Same […]
As part of the European Green Deal, the European Union intends to encourage green investments and prioritise the revision of the Non-Financial Reporting Directive (NFRD). The European or Green Taxonomy, which sets out a precise classification of sustainable activities with the strategic objective of redirecting capital flows towards those activities from 2022, is a result […]
The market is seeing a growing trend for real estate management companies seeking to speed up the process of closing their accounts. This is largely due to the positioning of real estate funds in life insurance contracts requiring increasingly shorter valuation intervals. Furthermore, as the regulatory obligation to publish Net Asset Values (NAVs) within the […]
As part of its rotating Presidency of the EU Council for a six-month mandate, France chaired its first EU Council of Finance Ministers (ECOFIN) meeting on 18 January with a view to getting certain current legislative work finalised. The ECOFIN meeting was mainly dedicated to introducing the Presidency’s roadmap for the months to come. Beyond […]
As regulated entities execute their post-Brexit strategies and relocate their European Union (EU) operations from the UK to other EU states, a key issue to be addressed for those relocating to Ireland remain to be the impending legislative changes surrounding increased accountability standards for executives and non-executives. Not least, the breaking of the participation link, […]
The great financial crisis triggered a massive wave of bankruptcies in the worldwide banking sector, affected not only large international banks such as Lehman Brothers but also local ones such as Northern Rock in the UK. Basel prudential standards are designed to cope with financial risks stemming from the global banking system without taking into […]
Supervisory priorities 2022-2024 In December 2021, the European Central Bank (ECB) and the national supervisory authorities of the Eurozone countries published their supervisory priorities for 2022-2024. The three-year coverage enables the ECB banking supervision to achieve good progress in addressing the identified vulnerabilities while at the same time affording enough flexibility in any corresponding actions […]
The growing importance of sustainability issues and the role of credit institutions in financing transformation places climate and environmental risks at the core of regulatory and supervisory scrutiny today. For some years now, the Network for Greening the Financial System (NGFS), comprising central banks and national supervisory authorities, has been working to enhance sustainability and […]
Financial institutions and non-bank financial technology companies (FinTechs) alike make extensive use of various machine learning models (MLOps) in core and non-core areas of their business. Banks, for example, rely on such models for a range of risk assessments, including predictive underwriting, credit risk management, suspicious and/or fraudulent activity management, fair lending compliance, derivative and […]
The Covid-19 pandemic has amplified technology’s impact on the banking sector, helping to prove that technology now stands at the core of business sustainability for banks. In their constant search for convenience, digitally-savvy customers have pushed banks’ focus towards providing global business solutions more than ever. A new normal has emerged: an environment where banks’ […]
The creation of a new Anti-Money Laundering Authority will transform the supervision of money laundering and financing terrorism (AML/CFT) in the EU. Proposed reforms also extend the AML/CFT rules to all crypto-asset service providers, as well as include specific rules concerning due diligence on customers and beneficial ownership. It is expected that some of these […]
On 22 September, the European Commission adopted a review of Solvency II following the consultation launched by EIOPA in 2020, whose final guidance was published in December 2020. As the Commission notes, the 2020 review of the directive met several objectives: • remove the obstacles to long-term financing of the economy and redirect investment by […]
The Financial Stability Oversight Council (FSOC) was established under the Dodd-Frank Wall Street Reform and Consumer Protection Act as a result of the 2007-2008 US financial crisis. A first of its kind, the 15-member council is tasked primarily with identifying growing systemic risks to US financial stability and proposing coordinated regulatory responses to both preempt […]
The widespread use of working from home (WFH) during the pandemic, regardless of sector or geographical location has required organisations and their information systems (IS) management to be very agile in deploying or increasing their capacity for remote collaboration. Some institutions were already prepared – for example, following the wave of strikes at the end […]
As the PRA transitions from a “rule-taker” to a “rule-maker”, small and medium-sized banks operating in the UK can expect to benefit from a more “streamlined” regulatory regime that could be easier to interpret, implement and maintain; but at the same time, they can also expect the PRA to be progressively more involved in scrutinising […]
The identification and management of non-performing loans or NPLs as early as possible by banks are among supervisors’ current high-level priorities. Indeed, when prudential, monetary, and fiscal crisis mitigation mechanisms are tapered, the weakening of borrowers’ creditworthiness could materialise, along with increasing credit risks and therefore NPLs. This expected rise of new NPLs in European […]
The unveiling of the new banking package “CRR3 – CRD6” on 27 October 2021 presents a further landmark on the road to implementing the final Basel III agreements. The regulatory scheme will also focus on the revision of the market risk framework from January 2019, as well as the latest developments in pillar 3 requirements. […]
The low level of banking consolidation in Europe compared to other countries is raising concerns among the supervisory community in Europe. It is a trend further reinforced after the financial crisis of 2007/2008 that produced a noticeable slowdown in consolidation operations in the EU. So what has been the impact, and what can we expect […]
Climate change introduces considerable economic challenges. On the one hand, financial institutions must contribute to the transition to a low-carbon and balanced economy to effectively combat global warming. On the other hand, the financial sector is exposed to climate-related and environmental risks and therefore needs to implement appropriate risk management practices within a financial stability […]
On 30 July, the European Central Bank unveiled the 2021 supervisory stress test results, which demonstrated that the region’s banking system is resilient in an unfavourable environment. The Common Equity Tier 1 (CET1) ratio has fallen 5.2% to 9.9% under the 3-year adverse scenario, while under the baseline scenario the CET1 ratio will reach 15.8% […]
The continued popularity of funds with an environmental, social and governance (ESG) focus has put global ESG assets on track to exceed $53tn by 2025, up from nearly $38tn at the end of 20201. As growth continues, expectations for effective compliance policies and controls in place are expected to become more rigorous as political and […]
A growing interest in environmental, social and governance (ESG) issues is driving record inflows into the ESG-led investment sector. During 2020, sustainable funds available to European investors attracted net inflows of €233bn1, which saw assets under management hit the $1.1tn milestone, accounting for almost 10% of total European fund assets. A similar growth story in […]
The recent breakthrough of data science and deep learning make a model independent approach for hedging possible. This hedging approach known as deep hedging is a robust data-driven method able to consider market frictions as well as trading constraints without using model-computed greeks. This article gives the main theoretical tools to understand the methodology and […]
A major step forward has been taken in implementing the European “investment firms” package in France*. The transposition of the package into local legislation, alongside EU Regulation 2019/2033 on prudential requirements for investment firms (IFR), came into full effect on 26 June 2021. In accordance with the proportionality principle, the IFR and investment firms directive […]
Recently, initiatives to tackle climate-related and environmental risks in the financial services industry have begun across the world. These initiatives followed the adoption of the United Nations Paris Agreement on climate change, the 2030 agenda for Sustainable Development and the European Green Deal. Stress testing and scenario analysis are a common framework proposed by different […]
Local and international trends have transformed the way banks operate, affecting their capital positions and profitability. In particular, ongoing digitalisation programmes and technological innovation continue to add pressure on traditional banking models, including the supply chain. While management’s focus on capital preservation, profitability and growth for shareholders remains, risks from an operational perspective have intensified. […]
With the current ultra-low interest rate environment and market volatility having a negative impact on banks’ returns and, ultimately, their capital positions, operating models must quickly adapt and become more cost-efficient to maintain profitability. This drive for cost-efficiency has become more apparent as innovation in technology and ongoing digitalisation have further upended traditional banking systems […]
Brexit, or the UK’s departure from the European Union, became a reality on 1 January 2021. In terms of the regulatory impact for the financial sector, and the banking sector in particular, the UK being a third country, UK banks can no longer benefit from the European passport for their continental activities. Therefore, they can […]
On 1 March 2021, the European Banking Authority (EBA) launched a public consultation on draft implementing technical standards (ITS) for Pillar 3 disclosures of environmental, social and governance (ESG) risks, under its capital requirements regulation (CRR) mandate. The consultation will end on 1 June 2021. Large banking institutions with securities traded on a regulated market […]
The digitalisation of banking processes and the introduction of AI-led technology impact the central and strategic role of information systems within the banking system. The growing use of information and communication technology (ICT) exposes all financial institutions to an increasing level of digital risk that could weaken their operational resilience, in particular, due to more […]
The Targeted Review of Internal Models (TRIM) was one of the largest projects by the European Central Bank (ECB) aimed at identifying potential sources of unwarranted or non-risk based variability in Significant Institutions (SIs) risk-weighted assets (RWA) from the use of Pillar 1 internal models such as Probability of Default (PD), Loss Given Default (LGD) […]
Click here to read ‘Key takeaways & industry challenges following the ECB TRIM project – a focus on credit risk (Part 2)’ As articulated by the ECB in its recent TRIM reporting, the 236 findings cover different key aspects of supervised entities Internal Model Method (IMM) models & frameworks. Remediation actions are underway in all […]
Against the background of a new year still severely affected by the persistence of the pandemic throughout the world and economies facing an unprecedented global macro-economic shock, the Basel Committee has felt it necessary to address the audit of the expected credit loss (ECL) accounting estimate within the overall financial statement audit. With IFRS 9 […]
Over the past decade, the financial services industry has been disrupted by the arrival of new players whose rise to prominence has pushed traditional banks – previously faced with little competition – to transform themselves. In this context, technology and innovation, particularly 5G, will allow the most skilful and agile banking organisations to take advantage […]
While 2020 went relatively smoothly for the banking sector, uncertainties remain on the potential effects of Covid-19 on the real economy. Any negative impact could lead to heavy losses for the sector, especially when support measures are gradually phased out. These measures have not only contained the anticipated increase in credit risks, but have also […]
On 13 November 2020, the EBA published the final methodological note for the 2021 EU-wide stress-testing exercise. The aim of the stress tests is to assess the resilience of financial institutions to adverse economic and financial developments, in particular in the event of an increase in credit risk due to the default of the borrower. […]
The publication on 29 January of baseline and adverse scenarios, output templates, instructions and market assumptions required to carry out stress tests signals the go-ahead by the European Banking Association (EBA) for the 2021 regulatory exercise. Because of the Covid-19 pandemic, these tests, originally planned for 2020, will take place between now and 31 July […]
With the economic repercussions of the Covid-19 crisis yet to be fully assessed, a robust resolution framework is essential to ensure the stability of the banking system. While the banks were given leave to postpone the reporting of some less urgent information in spring 2020, the Single Resolution Board (SRB) has reiterated the importance of […]
While there is a consensus about the smart building concept, there are still challenges to overcome if tomorrow’s buildings are enhanced to benefit the environment, cities and people. Starting with their design and throughout their useful lives, buildings have a huge impact on the environment and the quality of life of their users. So how […]
While digital transformation has been disrupting all business sectors for many years, 2020 will be remembered for its particular impact on real estate administrators. A third of French respondents believe that artificial intelligence can be more efficient than a real estate agent. Moreover, 40% of those under 50 years old are convinced that the property […]
European sustainable finance regulations evolved considerably in 2020, and the European Banking Authority (EBA) is continuing this trend into 2021. It recently published a discussion paper assessing the potential inclusion of Environmental, Social and Governance (ESG) risks in the supervisory review and evaluation process (SREP) performed by national competent authorities (NCAs)[1]. What firms need to […]
With more than half of the world’s fastest-growing economies located in Africa1, the continent’s economic outlook is a positive one. Average annual GDP growth since 2000 is over 5%, placing Africa as the second-fastest growing economy behind Latin America. Real GDP growth, estimated at 3.4% for 2019, is projected to accelerate to 4.1% in 2021. […]
This article is part of the series covering the impact of sustainable finance on the insurance sector. Read further:Part 1: Assessing the impact of sustainable finance on insurance entitiesPart 2: How the insurance sector is meeting ESG challenges Clarity of information provided to various stakeholders is a growing issue for financial organisations. Despite the efforts […]
This article is part of the series covering the impact of sustainable finance on the insurance sector. Read further:Part 1: Assessing the impact of sustainable finance on insurance entitiesPart 3: Developing a toolkit for responsible investment decisions When taking environmental, social, and long-term asset portfolio issues into consideration, insurance companies must assess the specific risks […]
This article is part of the series covering the impact of sustainable finance on the insurance sector. Read further:Part 2: How the insurance sector is meeting ESG challengesPart 3: Developing a toolkit for responsible investment decisions Amid a global pandemic and a rising threat of climate change, today’s society expects financial organisations to uphold strong […]
The working environment has always been an important factor for companies’ performance and their ability to attract talent. With the rise of remote work, this aspect has become critical: companies now have to ‘seduce’ staff to return to the office. Therefore, real estate services will play a crucial role in helping businesses upgrade working environments […]
The global real estate crowdfunding market was estimated at USD13.2bn in 2018 and is expected to reach USD868.9bn by 20271. In addition, the market is expected to grow at a compound annual growth rate (CAGR) of 58.3% from 2019 to 20271. In Europe, excluding the UK, real estate crowdfunding transaction value was USD600.1m in 20182. […]
In this edition of our Banking Regulatory Radar, we cover the key regulatory developments in the banking sector for 2020-2025. The latest version of the Mazars’ Regulatory Radar has been updated with all the Level 2 legislation published in 2020, as well as the measures that were taken in the context of the Covid-19 pandemic. […]
Facebook’s ambition to create a transferable global digital coin between users on the social media giant’s messaging platforms WhatsApp and Messenger has been controversial from the outset. Perhaps not surprisingly, the backlash from regulators around the world was substantial from day one. The world’s leading economies were less than enthusiastic of the possibility of a […]
The pandemic has had a significant impact on our entire ecosystem. We have seen global CO2 emissions fall by a record 7% in 20201 benefitting the environment. Yet, at the same time, we have seen adverse consequences for the mental health of staff working remotely, with almost half (49%) of those working from home saying […]
March 2020 marked the first time – since its inception in 2014 – that the Bank of England (BoE) cancelled its annual stress tests for the UK’s biggest lenders. Instead, they undertook a desktop analysis of the UK banking sector resilience. In late 2020, the Financial Policy Committee (FPC) judged that most banks have capital […]
Around one-fifth of global banking activity is undertaken in the UK. Almost half of the UK’s banking assets are held by international banks. The PRA currently supervises approximately 250 international banks, both branches and subsidiaries, which are part of around 180 international groups. Background On 11 January 2021, the PRA shared in a Consultation Paper […]
One of the anticipated challenges in the transition from IBOR rates to risk-free rates (RFRs) is the management of its impact on quantitative models. The ones currently used for pricing IBOR-linked financial instruments account for term rates which are “forward-looking”. The RFRs replacing the IBORs are all overnight rates. This means that a term rate […]
Under article 430c of the updated Capital Requirements Regulation (CRR 2), the European Parliament and the Council of the European Union mandate that the European Banking Authority (EBA) perform a feasibility study on reducing the reporting burden for the European banking sector while ensuring data collection for monetary policy, resolution and supervisory purposes and take […]
There is little doubt that Covid-19 has had a significant impact on insurers, but there were already factors in play that were adding pressure on the insurance industry. What covid-19 has done is to create new challenges, as well as bringing existing challenges to the foreground. Looking ahead, the actions insurers take now to deal […]
An important milestone in the IBOR transition is the change in rates used by LCH and CME for discounting and Price Alignment Interest (PAI) calculations for USD OTC cleared swaps. Indeed, on October 16, 2020, they moved from using the daily Effective Federal Funds Rate (Fed Funds) to the Secured Overnight Funding Rate (SOFR) for […]
As the world gears up for the transition to net-zero, the European Union is setting ambitious targets with respect to its own environmental footprint. For instance, by 2030 the EU is looking to reduce European greenhouse gas emissions by at least 55% compared to 1990 levels; increase the share of renewables within Europe’s total energy […]
In the early 1990s, stress tests became a popular internal tool for international banks to examine risks and gain a better understanding of threats to the institutions’ balance sheet. From there, the Basel Accord was amended in the mid- ’90s and required banks and investment firms to conduct stress tests. However, these were more internal […]
The revised market risk framework – also known as the Fundamental Review of the Trading Book (‘FRTB’) – not only impacts an institution’s regulatory capital charge calculation for market risk, but also affects operational, governance and business strategies. FRTB brings significant change. With the aim of harmonising capital standards for market risks across jurisdictions and […]
One of the major challenges of IBOR transition is the availability of historical data on alternative risk-free rates (RFRs) required to implement interest rate model changes or re-calibration. With the Secured Overnight Financing Rate (SOFR) only published since April 2018, the available time series do not provide enough observations for risk modelling. Adding to that, […]
Over recent years, technology and software have become strategic assets for competitiveness and resilience in the banking sector. Institutions have no choice but to invest to develop and deliver innovative services whilst managing ever greater IT and cybersecurity risks. The pandemic and announcement of lockdown measures posed a significant challenge for banks’ technology teams as […]
The Federal Reserve Board released stress test results for DFAST 2020 including additional sensitivity analysis, considering the COVID19 outbreak, to assess the resiliency of large banks under three hypothetical recessions, or downside scenarios, that could result from the coronavirus event. Furthermore, the Board provides guidance for large banks to maintain resiliency during economic uncertainties from […]
American entrepreneur, Malcolm Forbes, once described diversity as “the art of thinking independently together”. Today, diversity is beginning to emerge as a quintessential workforce norm and institutions have started to acknowledge the differences in their staff compositions that are deeply ingrained in the fabric of their organisational culture. With many challenges remaining, the independent think […]
With COVID-19, being declared a pandemic on March 11, 2020, financial institutions have had to shift most of their resources to mitigate the risks that have arisen. This has adversely affected important activities, one of which is market participants’ efforts to detach from LIBOR before its cessation at the end of 2021. As a result, […]
Impacts from the COVID-19 pandemic have reverberated across every part of the global economy. Small businesses are struggling to pay their employees, banks are grappling with collapsing local economies, and many borrowers across the nation cannot meet their monthly mortgage payments. Banks will play a critical role in supporting their communities through this crisis, and […]
During the last few weeks, the volume of loans issued by banks has snowballed as governments release programmes to bail out businesses affected by Covid-19. As a result of these higher volumes, the exceptional increase in underwriting activity raises several issues for banks. Most notably, banks, like all commercial institutions, are also having to cope […]
Gender equality, while not systematically embedded in national laws, is clearly set in European law. The Capital Requirements Regulation (CRR) requires financial institutions to adopt a policy promoting diversity within their management bodies and, for the most significant ones, to set targets to reach gender-balanced boards. Despite these regulatory requirements, the conclusions of the European […]
The Risk-Free Rates Working Group (RFRWG) published an update on the impact of COVID-19 on the timeline for firm’s plans to transition away from GBP LIBOR on the 29th April. While the central assumption of LIBOR’s publication being ceased after the end of 2021 remains intact, the Working Group has amended the timeline for the […]
What is the purpose of a bank? Does it have a responsibility to society at large, over and above its duties to its shareholders, customers and employees? The purpose of banks – to make a profit or be socially useful? What is the purpose of a bank? Does it have a responsibility to society at […]
Pierre Latrobe at Mazars discusses recent HKMA initiatives taken in response to Covid-19 and their implications for Hong Kong banks, highlighting credit risk as a growing threat. The Hong Kong economy has been confronted by several downside factors over the last two years. The first hit was the initiation of the US trade war with […]
The Alternative Reference Rates Committee (ARRC) continues to support market participants in their efforts to transition from USD London Interbank Offered Rate (LIBOR) towards the Securities Overnight Reference Rate (SOFR). Following the Financial Conduct Authority’s (FCA) March 2020 statement that the expected LIBOR cessation deadline remains unaltered – i.e. end of 2021 – ARRC published […]
At first glance, regulatory authorities appear to have deprioritised the issue of climate change. However, a closer look would suggest otherwise and climate change in reality remains a key long-term priority of national and European regulators. In some areas, regulatory action on climate change has been delayed Central banks around the world have taken steps […]
The current pandemic is having far reaching consequences across all aspects of society. Compared to other industries the impact on the credit card industry is relatively mild and from a customer perspective the value of on-demand liquidity is now clearer than ever. However, there will be significant impacts on industry profitability. Reduced international travel will […]
Covid-19 disruption to the banking sector is widespread, including changes to working patterns, changes in customer behaviour, changes to partner-supplier dynamics and direct impacts on profit and loss accounts. The phase of immediate action to ensure business continuity is now largely complete. As infection curves flatten, restrictions are gradually eased and light starts to emerge […]
With banks no longer the weak link in the financial system, they now have a key role to play in supporting the real economy to survive the crisis caused by the Covid-19 pandemic. The significant strengthening of prudential regulation over the past decade since the 2008 financial crisis has enabled banking institutions to post solid levels […]
As we continue to feel the effects of the global pandemic, the banking sector, like many other sectors, now faces unprecedented uncertainty about the economic outlook ahead. While banks go into this pandemic in a stronger position than the global financial crisis of 2008, the current environment presents particular challenges and disruption to standard accounting […]
The European Securities and Markets Authority (ESMA) has issued a public statement to announce the delay of the industry’s compliance with phase one of the Securities Financing Transactions Regulation (SFTR). This is in response to ESMA’s awareness of the financial industry’s struggle to devote resources to comply with the new reporting obligation, as firms face […]
The Covid-19 outbreak and the unprecedented emergency it presents has created a unique threat to the world’s economy. Like all sectors, banking has been impacted, and its stakeholders have felt excessive pressure over the last few weeks to get things right. Regulators in financial markets around the globe have all announced Covid-19 action plans, which […]
The expected 2021 disappearance of LIBOR requires robust fallback language for cash products and derivatives alike. Industry associations have taken initiatives to reform the historic fallback language of securities, with ISDA proactively leading the way on derivatives and national working groups proposing enhancements for cash products. While the derivatives market is expected to be harmonized […]
Since Libor was first used in financial markets in 1986, it has become the foundation of the global interbank funding market. However, regulators ruled that Libor’s volatility during the last global financial crisis (GFC) and a rate-rigging crisis in 20121 involving the world’s largest banks exposed a fundamental weakness with the rate’s publication methodology. Yet, […]
One year on since the HKFRS 9 standard on financial instruments came into force in Hong Kong and two years since the First Time Application (FTA), trends and insights into impacts of the standard are beginning to evolve. As a reminder, the standard introduced numerous changes with regard to the classification, impairment recognition and the […]
In recent years, disruption to the banking sector has seen an increasing number of partnerships between banks and FinTechs, as banks look to acquire the digital expertise now required for 21st century banking and FinTechs look to tap into the finance knowledge and consumer reach that traditional banks enjoy. More recently, this quest for technological […]
At the end of nearly two years of legislative work, the reform of the prudential regulation of investment firms completed its final phase with the publication in the Official Journal of the European Union of two new regulatory texts: Regulation 2019/2033 on the prudential requirements of investment firms (IFR), and Directive 2019/2034 on the prudential […]
Under the terms of the Fundamental Review of the Trading Book (FRTB), a bank wishing to apply the Internal Modal Approach (IMA) to calculate its capital charge associated with market risk must carry out: backtesting on the Trading Book (TB) and for each trading desk (TD), two profit and loss attribution (PLA) tests for each […]
With Libor’s cessation date at the end of 2021 looming, global regulators are hastening their IBOR fallback strategies. Yet while market momentum has increased for multiple published RFR indices, among them the GBP SONIA, the EUR €STR, and the USD SOFR, Asian economies, some of which rank among the world’s largest, continue to lag. While […]
Financial market participants – at least the largest ones – are actively preparing for the expected discontinuation of the London Inter-Bank Offered Rate (LIBOR) after 2021. Transitioning towards a LIBOR-free world is a challenge that requires the involvement and coordination of the whole industry in order to find appropriate solutions to replace the 35 different […]
The methodology for an exercise to assess the resilience of EU banks to adverse market conditions and test the state of their capital allocations has been released by the European Banking Authority (EBA). The exercise – part of EU-wide stress testing – will apply to broadly 70% of the European banking sector[1]. Some 52 banks […]
Persistant negative interest rates, the inherent risk of a trade war between China and the United States, fears of a recession… all worrying signs of an imminent new crisis. However, the real question is not if but when the next crisis will hit. More than ten years after the financial and sovereign debt crisis, it […]
With little more than two years to go, Libor’s cessation date continues to near. The voluntary agreement of panel banks submitting to Libor will conclude at the end of 2021, from which risk-free rates (RFR) are expected to replace Libor and similar indices. Are corporates paying enough attention to Libor updates? Libor’s cessation should be […]
Pierre Latrobe at Mazars discusses the measures the HKMA has taken so far to strengthen its macroprudential supervisory toolkit and address potential risks to the wider financial system. The Hong Kong economy is suffering from several lingering negative factors, the US-China trade war, the global economic slowdown and the ongoing protests, to name but a […]
With significant IBOR reform on the horizon, Mazars brought together industry experts, practitioners and regulators to discuss the challenges and opportunities they face. Speakers included the Bank of England Market Division’s Alastair Hughes, EFRAG’s Didier Andries and Mazars’ IBOR lead, Pauline Pelissier. From a comprehensive and illuminating session, Pauline sums up the key takeaways: “What […]
The British political landscape has been unsettled and uncertain. Boris Johnson defeated Theresa May in July 2019 to become Prime Minister with his “do or die” conviction for the UK’s exit from the EU, with or without a deal. While the Government has been successful in achieving Parliament’s support for a renegotiated withdrawal deal, MPs […]
In 2018, the Bank of England (the “BoE”) set up a project called “Future of Finance” aimed at anticipating the upcoming changes in financial services for the next decade, and the impact of these changes for market participants, customers and regulators. This research was led by Huw van Steenis, Senior Adviser to the Governor, and […]
Robotic process automation (RPA) is software that sits on a PC or workstation and is programmed to mimic the activities that a member of staff would perform. It will open applications, copy and paste data, and follow predefined rules. A robot will complete activities three to five times faster than a person. Customer satisfaction can […]
Whether the launch of Facebook’s Libra will threaten global monetary and financial stability is a question that has been on all regulators’ and politicians’ minds since Facebook announced its cryptocurrency project on June 18, 2019. Donald Trump himself tweeted that, as a virtual currency, Libra “will have little standing or dependability” and that Facebook should […]
September 2018 saw the tenth anniversary of the collapse of Lehman Brothers, the US corporate and investment bank that was symbolic of Wall Street. Its failure is still fresh in the mind, and marked a turning point for banking and financial regulation. The disappearance of Lehman launched a cycle of “re-regulation” intended to increase the […]
A raft of recent consultations on Ibor reform indicates that we may finally be making some progress. We have seen the International Swaps and Derivatives Association (ISDA) issue another round of consultations for Inter-Bank Offered Rates (IBORs) trying to solve the issue of the spread and term adjustments in fall-back for derivatives referencing IBORs and […]
The standard IFRS 16 on leases is applicable to financial periods current at 1 January 2019. It applies to listed companies, their consolidated subsidiaries and entities presenting their accounts under international financial reporting standards (IFRS). The standard seeks to improve the presentation of leases in the accounts, and requires lessees (tenants) to account for leases […]
Mass data… The real estate sector is gradually going digital, and recent constructions now incorporate equipment and connectivity to allow both use and maintenance to be optimised. However, as the renovation of the stock is naturally slow, the majority of these assets are not “connected”. Nevertheless, a great deal of data is available and constitutes […]
During a meeting of the Special European Council on the 10 April 2019, EU leaders agreed to a flexible Brexit extension until 31 October 2019, to allow for the ratification of a withdrawal agreement. Despite this extension, there is still great pressure on Theresa May to secure a deal before the EU Parliament elections are […]
New technology, regulatory developments and societal changes, including those linked to strengthening stakeholder engagement, are substantially impacting financial services as well as the rest of the business community. For businesses to succeed in this fast-changing environment they must be led effectively by their boards and successful in seizing opportunities and managing the risks confronting them. […]
With 2019 marking a move for the European Banking Authority (EBA) to Paris in April, regulatory priorities will see the EBA preparing the work of transposing the last Basel III agreements. Following a quantitative and qualitative study, the Commission will be awaiting its opinion in or after June 2019. Further, in the context of EBA mandates […]
Brexit preparation is one of the largest undertakings that regulators and market participants have ever done, considering the uncertainty and the impact it carries. Many financial institutions have stopped waiting for lawmakers to finalise negotiations over the terms of the exit and are already working towards contingency plans. Banks and brokers are setting up new […]
At the last G20 summit in Buenos Aires, leaders called for the full implementation of all major international financial reforms intended to improve the financial system, in particular, those drawn up by the Financial Stability Board (FSB) and the Basel Committee on Banking Supervision (BCBS), the last being the review of market risk framework published […]
On March 11 and 12, 2019, Mazars attended the 30th annual conference organized by the Institute of International Bankers (IIB). Agencies and regulators serving as speakers and panelists this year, included: •The Federal Reserve Board (FRB) •The Department of the Treasury •The Commodity Futures Trading Commission (CFTC) •The Securities and Exchanges Commission (SEC) •The Office […]
Today’s world is witnessing an explosion of data, including personal data: your civil status, what you do and don’t like, your holidays, your favourite leisure activities. The exploitation of all this data is multiplying through the use of innovative IT tools. [pukka_pullquote width=”300″ txt_color=”#ffffff” bg_color=”#2d2d2d” size=”24″ align=”left”]”A pessimist sees the difficulty in every opportunity; an […]
Following a majority vote against Theresa May’s Brexit deal on 15 January 2019, and with only 3 weeks until the proposed deadline of 29 March, financial services authorities in the UK and EU have been urgently preparing for an increasingly likely no-deal Brexit, announcing further transitional instruments and offering guidance to firms within the sector. […]
Could the transition period towards the new alternative Risk-Free Rates (RFRs) be more complex than initially envisaged? The speech given by Edwin Schooling Latter, Director of Markets and Wholesale Policy at the Financial Conduct Authority (FCA), on the 28 January 2019, suggests this might be the case. While Mr Latter re-affirmed that the key focus […]
The financial sector is bursting with disruptive Fintech start-ups at present who are shaking up the banking and insurance sector with innovations varying from online mortgage banks to online payment services. With innovation occurring at such a rapid pace, how are banks responding? To some extent, the arrival of the revised Payment Services Directive (PSD2) […]
Seven years after the first Basel Committee on Banking Supervision’s (BCBS) consultative paper on the Fundamental Review of the Trading Book (FRTB) and three years after the publication of the revised Market Risk Framework, is the 14 January 2019 release of the final Minimum Capital Requirements for market risk the end of this particular regulatory […]
With rising global temperatures[1] comes an ever-growing pressure on the financial services sector to respond and prepare for the far-reaching effects of climate change. The impacts upon the sector are already being felt – extreme weather events are creating significant losses for insurers and credit risks for banks, and pressures on businesses to demonstrate sustainable […]
Which is the more significant – the tenth anniversary of the collapse of Lehman Brothers, or the tenth anniversary of the opening of the App Store? For the global financial community world, 15 September 2008 is a key date, weighted with as much symbolism as the great stock market crash of 24 October 1929 had […]
In the second installation to our Brexit Watch, the delay of the House of Commons vote and subsequent negotiations increases uncertainty, with multiple possible scenarios set to emerge. Brexit preparation has been one of the largest undertakings for regulatory bodies on both sides of the channel. Despite continued unpredictability surrounding outcomes, new directives and amendments […]
On Friday 2 November, as expected, the European Banking Authority (EBA) published the results of the 2018 EU wide stress tests on European banks’ solvency in the event of macro-economic shocks. This was the fourth exercise of the now-biannual testing which has been carried out on European Union banks. Despite more severe tests than in […]
The sweeping growth and prolific collection of technologies that make up cryptoassets today have made it incredibly challenging for regulators worldwide to standardize and issue authoritative guidance. Professional accounting standard-setting bodies, like the Financial Accounting Standards Board (FASB) and the International Accounting Standards Board (IASB) are certainly no exception. What started out as just bitcoin […]
As negotiations on the UK’s exit from Europe continue, albeit slowly, regulatory bodies in the UK and Europe are beginning to issue regulatory changes to cope with all eventualities, including the UK leaving Europe without a deal. As a result, a number of new directives and amendments to regulations have been issued over the summer […]
With a portfolio in excess of €1300 billion in 2017, euro savings are firmly established as the preferred life-insurance product for people in France, thanks to their threefold benefits of guaranteed capital, attractive returns and instant liquidity. However, recent financial and regulatory developments raise questions as to the legitimacy of this product in the savings […]
Integrated Reporting applies principles and concepts that are focused on bringing greater cohesion and efficiency to the reporting process, and adopting ‘integrated thinking’ as a way of breaking down internal silos and reducing duplication.The Framework has been tested and assessed during these past three years and significant ‘breakthroughs’ have been achieved. Our present paper, therefore, […]
The new standard IFRS 9 on financial instruments has been effective starting 1st January 2018 for most entities but insurance groups have the possibility to defer its application to 2021, the year when the new standard IFRS 17 on insurance contracts will enter into force. IFRS 9 introduces numerous changes (Phase 1/ classification, Phase 2/ […]
Reinsurance, also known as the “ insurers’ insurance ”, plays a key role in the global market economy today. Several factors, such as the strengthening of capital requirements, the increasing level of significant NAT CAT events or the need for optimal coverage is increasing the need for reinsurance. Initially, insurance companies sought partnerships with reinsurers […]
While 2018 has witnessed some turmoil in the crypto-currency markets, interest in this new asset class – and also in investment funds which allow easy access to crypto-currencies – remains high. On 26 June 2018 CBOE Global Markets filed an application with the US Security and Exchange Commission (SEC) seeking approval for a Bitcoin Exchange […]
Tax legislation generally includes promises to simplify the process of computing taxes. But in the process of transforming legislation into law, those good intentions often are overshadowed by new complexities. The Tax Cuts and Jobs Act of 2017 is no exception, especially for U.S. multinational corporations. Although most corporations herald their much lower 21% tax […]
The whole financial system relies on reference interest rates, more precisely on InterBank Offered Rates (IBORs) whose integrity and reliability have raised some concerns since the 2008 financial crisis and the LIBOR manipulation scandal. These IBORs are used to determine the unsecured short-term funding cost in the interbank market for a combination of currencies, tenors […]
After many years of development, in May 2017, the International Accounting Standards Board (IASB) published a new standard for insurance contracts. Coming into effect on January 1st 2021, the IFRS 17 standard introduces a new model for accounting and measuring insurance liabilities with a framework which is substantially different from current accounting practices. While the […]
S.1255 the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Senate Banking Bill”) was passed on March 14, 2018 after a strongly bipartisan 67-31 vote. On May 22, 2018, the House passed the Senate Banking Bill with 258 yeas (225 Republicans and 33 Democrats) and 159 nays (1 Republican and 158 Democrats). The bill […]
Fintech is prominent in today’s business lexicon, having migrated from the back office to a prominent position in both consumer and commercial finance. Its core functionality on mobile devices and wide application in artificial intelligence (AI) spans blockchain, smart contracts, banking, insurance, regulation and cybersecurity. And Amazon Web Services (AWS), a major cloud player, is […]
In this podcast, Greg Simpson discusses the Prudential Regulatory changes proposed by Basel 3. Together with Phuong Gomard and Bowen Lu, regulatory specialists in Mazars’ Banking Consulting practice, they highlight the impact on the standardised approach to credit risk and operational risk. Whilst relevant to all UK banks, it is particularly relevant to smaller challengers and […]
The FinTech model is reaching a new level of maturity. The first stage saw them disrupt the traditional banking business models using technology to impact the customer experience and relationship. The second wave offers FinTechs the opportunity to expand their service offering and develop their independence, provided that they understand their relationship with the regulatory […]
Within the insurance industry, automatic exchange of information under Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) is mainly relevant to life insurers, since non-life insurance and reinsurance activities generally do not give rise to classification and reporting obligations under these regulations. Life insurance activities (technically, the fact of issuing or […]
The complexities of creating and implementing a due diligence framework to monitor and measure the impact financial services have on human rights can be overwhelming. The EU recommended UN Guiding Principles on Business and Human Rights Reporting Framework (www.UNGPreporting.org) – co-authored by Mazars and Shift – , as well as the EU Non-Financial Reporting Directive […]
Prominent real estate owners and developers are sourcing an attractive form of capital—bonds issued and traded on the Tel Aviv Stock Exchange (TASE). It’s a creative concept, with benefits for both sides of the transaction, and is also attractive for U.S. listed Real Estate Investment Trusts (REITs), enabling them to issue bonds in Israel while […]
Big data analytics is one of the most discussed topics in the world of finance. Application of these methods has led to better assessment of credit quality, improved pricing of insurance contracts as well as automation of client interaction. Processes that were previously cumbersome, such as customer on-boarding, have been streamlined and their costs drastically […]
By Bisnow, sponsored by Mazars New York City was both the most liquid hospitality market in the country[i], and global hotel investors’ destination of choice in 2015, according to JLL. That year, its transaction volume exceeded $6.6B, outpacing London by 40% and eclipsing its own 2011 record of $3.1B. Although total hotel deal volume decreased […]
The Tax Cuts and Jobs Act (the “TCJA”), signed into law in December 2017, and applicable to taxable years beginning after December 31, 2017, contains several provisions that will have a significant impact on specific types of entities and investments. One of the most radical departures from current law involves new limitations on the deductibility […]
By Bisnow, sponsored by Mazars Millennials have surpassed baby boomers as the largest living generation[i], and they are spending a larger share of their incomes on experiences[ii] like travel and dining than on possessions. Winning over this generation, which controls a growing share of the nation’s disposable income[iii], is important for hotels’ profitability and long-term […]
It is truly amazing the turmoil 88 pages can produce. Yet while the whole Banking Industry is strongly opposed to some of the new Fundamental Review of the Trading Book (FRTB) requirements, such as the Profit & Loss Attribution (PLA) test, could the EU Council now be considering to only include reporting requirements in CRR2? […]
On February 1, 2018, just one day after the European Banking Authority (EBA) officially kicked off its EU-wide stress test exercise, the Federal Reserve Board (FRB) released the applicable scenarios for its own US stress test. 2018 US Stress Test Scenarios Overview The annual stress test exercise is required by a provision of the Comprehensive […]
The Solvency II Directive increases the requirements for transparency vis-à-vis both the regulatory authorities and the stakeholders, including policyholders, financial analysts and investors. In this context, insurance undertakings and groups were, for the first time, required to publish a narrative report no later than 19 May 2017, known as the Solvency and Financial Condition Report […]
At the end of February 2018, all the major European banks published information on the impact of the implementation of the new standard IFRS 9. IFRS 9 introduces numerous changes (classification, impairment, hedging, etc.). Their impacts at the transition date vary widely from one bank to another. They are negative in most cases, but for […]
On 6 February 2018, EIOPA published its latest risk-free interest rate curve to be taken into account for the purposes of Solvency II calculations. Based on calculations for January 2018, the curve is slightly different from previously published curves. This is reflecting significant changes in the long-term expectations of interest rates in recent years which calculates […]
Because of the 2008 financial and economic crisis, banks have accumulated billions of non-performing loans (NPLs) on their balance sheets. Even 10 years after this major economic event, the situation is not yet back to normal in some countries. In the European Union, and in the Eurozone particularly, NPLs are a real concern as they […]
Because of its importance in society, the insurance industry has always faced a considerable amount of regulatory requirements at the national (BaFin) and international (EIOPA) level. Although this is generally something to be welcomed, this also presents a range of different challenges – not least because the regulations have indirect effects and unintended side effects. […]
Digital transformation has expanded the need for security, continuity and resilience. Today’s business must embrace an enterprise risk management strategy that includes legal, regulatory and political considerations. Enterprises today face a significant level of security challenges across their organizations. IT is no longer a secondary priority; it is now at the very heart of the […]
In recent years, we have seen a tremendous surge of interest in measuring and managing operational risks, both as a result of regulatory developments in corporate governance and capital adequacy, as well as due to a growing realisation that an enterprise-wide view of risk management is simply good business (those familiar with ISO9001 Quality Management […]
While whistleblowing laws and initiatives might differ from country to country, whistleblowers in the financial industry are now well recognized and have gained international attention. Here we analyse the steps taken in the USA to strengthen whistleblowing procedures and practices. Recent allegations of impropriety on several levels have rekindled whistleblowers as a mechanism for identifying […]
On 7 December, after several years of negotiations (starting in 2012 with the market risk review), Mario Draghi, chair of the Basel Committee’s Group of Governors and Head of Supervision (G-HOS), announced the finalisation of the Basel III agreements. These represent the final stage in the post-financial crisis reforms to the prudential regulations. For the […]
In the financial industry in general and the insurance sector in particular, traditional business models are increasingly coming under pressure – a trend that reflects technological, economic and social changes. At first glance, this represents a risk for insurance firms, since conventional business models such as life assurance are hardly profitable in this new environment. […]
Non-performing loans (NPLs) remain at the forefront of the European regulatory agenda, with two major consultations run by the European Central Bank (ECB) and the European Commission (EC) over the recent weeks, both in relation to the introduction of minimum prudential backstops. NPLs, a longstanding hot topic in Europe In the aftermath of the great […]
PSD2 will supersede PSD1 on 13 January 2018, retaining key benefits from PSD1 such as increased competition with facilitated market entrance for regulated non-bank players, improved economies of scale, enhanced transparency, but also incorporating technological innovation, enhancements and protection into law. This will ensure that a competitive playing field continues to develop, without exposing individuals, […]
The new Investment Tax Act in Germany introduces new rules on investment taxation in the country. Coming into force on 1st Jan 2018, a widespread reform will apply to domestic and foreign investment funds with the transfer of transparent to non-transparent taxation status at fund level at a rate of 15% plus solidarity surcharge. Importantly, […]
The vast array of legal and supervisory requirements for determining a business model draws attention away from the inherent and indispensable need that a successful entrepreneur has for such a model. In the past, was an entrepreneur who had decided to run a bank ever asked about their business model? What is a business model? […]
In this third article of our thought leadership programme around the transformation of Financial Services, we are focusing on how new business models are emerging. “THIS IS A WORLD OF SIX-MONTH PRODUCT DEVELOPMENT CYCLES AND CONSTANT UPDATES, PRIMARILY OF SOFTWARE, WITH A HUGE PREMIUM ON SIMPLE USER INTERFACES AND TRUSTED SECURITY.” Christine Lagarde, Managing Director […]
I was recently invited to speak at the 25th birthday conference of the Bulgarian Insurance Association in Sofia. The request came from my colleague, Thanos Petropoulos, who runs Mazars Bulgaria. As an integrated, international partnership, opportunities to work with our colleagues across borders is one of the most enjoyable parts of working at Mazars. This […]
As recent as 26 September 2017, the European Banking Authority (EBA) under the Directive 2013/36/EU published its revised guidelines on harmonising the internal governance arrangements of banks across the European Union. The EBA Guidelines will apply as of 30 June 2018 to competent authorities across the EU, as well as to institutions on an individual […]
One of the main differentiators FinTechs have is their current positioning within the financial services value chain ecosystem: they focus on customer experience while their operations execution and control activities are often outsourced to banking institutions. However, is this likely to remain given the increasing interest regulators are paying to these new industry players? While […]
A holiday photo on Instagram, a “like” on Facebook, a PayPal transfer to pay for your Airbnb, or just a bank card payment or an ATM withdrawal: every day, we feed data into greedy and enthusiastic algorithms that are gathering our personal information. A new European regulation adopted in response to this irrational frenzy, the […]
On September 27, 2017, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (the “Banking Agencies”) issued a proposed joint rule to simplify several requirements in the Banking Agencies’ regulatory capital rule for banks. The proposed rule would apply only to banking organizations that are not […]
In August 2017, S&P Global Market Intelligence published an analysis of where banks will set up their European hubs. Germany, namely Frankfurt and Berlin, came first with 13 financial institutions. Dublin came a close second attracting 12 banks, insurers or asset managers. Luxembourg, France, the Netherlands and Belgium will also take a share. A bit […]
A new prudential framework applicable to banks and credit institutions in the West African Economic and Monetary Union (WAEMU) is set to come into force on 1 January 2018. However, a significant delay has been observed in implanting reforms in the majority of banks, where the scale and implications of the necessary work are widely […]
Reforms to an accounting system that has been in force for nearly 20 years will help to increase the security and robustness of the West African financial system, while improving the quality of financial reporting. The Revised Banking Chart of Accounts has been adopted by the monetary authorities in the course of convergence towards Basel […]
Despite “reform fatigue” and squeezed profit margins, financial services firms are dealing with a continued flood of regulation. Some are turning to new technologies for compliance help. In this article, written by the Economist Intelligence Unit and sponsored by Mazars, we explore regulatory change in the financial services sector and the impact that it has […]
The term “ICO” is a common buzzword in investment circles these days. While these “Initial Coin Offerings” are distant cousins of IPOs (in the sense that both share the objective of helping firms raise capital from various sources), their likely timing and means of achieving funds are quite different. An ICO is a form of […]
Over a decade ago looking at the state banking webpage for my home state of New Jersey, there were approximately 250 banks doing business in the state then. A similar check today would yield a list of less than 150 or so; a more than 40% decline. With banking regulation at an all-time high, the […]
The FX Global Code (Code) was finally published by the Foreign Exchange Working Group (FXWG)[1] on 25th May 2017, clearly laying down the guidelines for good practices in the FX Wholesale marketplace. With numerous scandals causing turbulence in the FX marketplace in the past, it was deemed necessary for global bodies to roll out a […]
Along with Mazars banking regulatory advisory specialists Pauline Pelissier and Audrey Cauchet, Greg Simpson provides an overview of the banking regulatory outlook in the UK and Europe over the next 12 to 18 months. They also discuss IFRS9 in the context of regulatory treatments, credit risk management, non-performing loans, CRD5 and CRR2. Podcast player
The Asset Management industry is positioned to be the main focus of the Financial Conduct Authority (“FCA”). On 28 June 2017, the FCA published the final report of its Asset Management Market Study. This follows on from the interim report published in November 2016. In the publication, the FCA has highlighted a number of pertinent […]
The lines between financial services and high technology are becoming increasingly blurred. Four major technological changes will disrupt financial services in the years ahead. In this article, written by the Economist Intelligence Unit and sponsored by Mazars, we are discussing how technological disruptors are impacting the global financial services industry. We review how C-suite financial services executives, […]
With Solvency II fully in force, the insurance industry has entered a new phase of transformational development. For many insurance companies, Solvency II has provided the opportunity to make better sense of risk and yet, insurance companies continue to operate using risk management programs that have not evolved and may not protect them from the […]
In this podcast Greg Simpson discusses cyber security with our expert Francisco Sanches. They discuss major threats such as emerging risks, FCA guidance on cloud data storage and the cyber security skill gaps to name a few. Podcast player
Measuring banking risks is a difficult exercise, but striking a balance between simplistic and overly complex measurement techniques is the key to accurate risk measurement. This was the substance of the European Central Bank’s (ECB) Chair of the Supervisory Board, Danièle Nouy, in a speech at the Austrian Chamber of Commerce in Vienna, on 2nd […]
Efficient supervision of capital markets is a priority of the Capital Markets Union (CMU) given its role in facilitating market integration and European cross-border transactions. But there are currently a number of supervisory barriers halting progress of European mobilisation of capital that now need to be addressed urgently. Following discussions at the CMU’s mid-term conference […]
The field of money remittance transactions in Japan is expanding and is attracting many overseas companies looking to operate fund transfer and virtual currency exchange businesses. A regulatory framework for FinTech firms in Japan now presents major opportunities and challenges, not just in Japan, but for regulators around the world. To support progress and development […]
Greg Simpson, Head of Banking UK and banking experts Paul Hodgett and Pierre Latrobe discuss the implications of IFRS9, more specifically they share some of their experience on helping banks implement IFRS 9. As the standard starts on 1 January 2018, they will also comment on some of the areas that banks need to consider […]
Personal data security is increasingly important, but many companies may not be ready to comply with the EU’s tough new data protection laws, which must be implemented by May 2018. All EU businesses that handle data will have to comply with the General Data Protection Regulation (GDPR), which will require investment in systems and training […]
Cyber as an organsational risk In 93% of data breaches, the targeted systems were compromised within minutes. 83% of the time, those breaches were not discovered for weeks, leaving the attackers with plenty of time to do their damage and exfiltrate data[1]. The average consolidated total cost of a U.S. data breach in 2016 was […]
Solvency, liquidity, transparency and oversight requirements: as the Basel Committee meeting in Santiago, Chile in November 2016 demonstrated, there is still much to be discussed on the finalisation of the Basel III agreements. However, the inauguration of the new President of the USA could change the condition of the international dialog. Some might decide to […]
Examination Cycle for Certain Small Insured Depository Institutions and U.S. Branches and Agencies of Foreign Banks Under $1 Billion in Total Assets. The Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) issued joint final rules that increased the number of small banks and […]
In about nine months, IFRS 9 will replace IAS 39 and the new accounting environment won’t be the only element to be impacted. In recent months, the Basel Committee on Banking Supervision (BCBS), the EU Commission and the European Banking Authority (EBA) have also been tackling the impact of the new IFRS 9 provisioning on […]
The figures speak for themselves: real estate investments in Germany rose to almost €66 bn in 2016, reaching almost €20 bn in the final quarter excluding residential, according to BNP Paribas Real Estate. Germany is now challenging the UK as the main European market, and some see it as the safest investment area following Brexit. […]
There is a clear pipeline of jumbo disposal Non-Performing Loans (NPLs) in Italy, thanks to the ECB push, however vendors will need to take into careful consideration a few factors in their decision, such as recent regulatory reforms of insolvency and foreclosure and a possible EU bad bank. 1. ECB Push Europe’s NPL assets are […]
After the Basel Committee consultation in October and then the European Commission’s legislative proposal of the package CRR II / CRD V in November 2016, the EBA has now given its opinion on the management impact of IFRS 9 on regulatory capital, notwithstanding a second impact study has just been completed. This opinion, primarily addressed […]
German Immobilien-Sondervermögen are domestic open-ended real estate funds without legal personality which are managed by an investment management company on behalf of its investors. It is the investment management company that buys, sells and manages property held within the fund according to the stated investment policy. The investment management company is the civil owner acting […]
Background and issues The Cambridge dictionary defines ‘infrastructure’ as ‘the basic systems and services that a country or organisation uses to work effectively’. This rather broad definition covers a wide range of assets at the heart of economic activity: they do not just provide a service to an individual or enterprise, but to economic agents […]
We look at the rise of ‘robostocks’ and algorithmic trading, and consider the repercussions on financial markets. An old investment adage mockingly states that “a failed trade becomes a long term investment”. The idea behind it is that if a security is bought and underperforms, investors tend to keep it until it eventually becomes profitable, […]
Real estate structures and tax treaty issues: questioning current thinking Real Estate Investment Trusts (“REITs”) give all investors the opportunity to invest in large-scale, diversified portfolios of income-producing real estate in the same way they typically invest in other asset classes – through the purchase and sale of liquid securities. Qualifying REITs are also tax […]
The Securities and Exchange Commission (“SEC”) approved a plan on November 15, 2016, to create the consolidated audit trail (“CAT”), a central data source to collect and accurately identify every order, cancellation, modification and trade execution for all exchange-listed equities and options across all U.S. markets. This plan is pursuant to SEC Rule 613, in […]
The principle of tax transparency for investment funds will soon be replaced by taxation at fund level with partial exemption for investors. This will also apply to foreign funds with German income. The new rules have been integrated in the completely revised German Investment Tax Act (Investmentsteuergesetz). This will lead to a complete change in […]
Cyberattacks aren’t just getting more frequent, they are also becoming significantly more vicious and sophisticated. The majority of today’s data breaches result from human error, making cybersecurity a “people problem” as well as a technology issue. The solution to this people problem can’t be solved by purchasing new hardware or software or implementing sophisticated network […]
Non-Performing Loans (NPLs) are a key issue and will continue to be on the European agenda as a top priority for a long time. On the one hand, the ECB guidelines are already applicable, as they represent a best practice reference for the day-by-day work of the Joint Supervisory Teams. On the other hand, the […]
On Wednesday 23 November, the European Commission presented its long-awaited revision of the Capital Requirements Regulation (CRR) and Capital Requirements Directive (CRD IV), including the regulatory changes that mark the finalisation of the Basel III agreements. This revision follows five years of consultations conducted by the Basel Committee. It aims to foster financial stability and to enhance […]
In May 2014, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (“ASU”) 2014-09, Revenue from Contracts with Customers. Topic 606, Revenue from Contracts with Customers, presents the new revenue recognition guidance. FASB also issued ASU 2015-14, Revenue from Contracts with Customers (Topic 606): Deferral of the Effective Date, in August 2015. As a […]
The European Central Bank (“ECB”) recently launched public consultation on guidance to banks on non-performing loans (“NPL”). Consultation periods runs until 15 of November 2016. As NPL harms the profitability, funding and capital of banks and more globally the real economy, the ECB issued this guidance, aiming to achieve common practices for how to handle […]
On 1 January 2018, banks applying IFRSs move into a new era with the implementation of IFRS 9 on financial instruments, which will supersede the existing IAS 39. Although adopting this new standard will lead to many changes, it was phase 2 of the standard, on provisions, that interested the Basel Committee on 11 October, […]
On 20th October, I was delighted to chair an event in collaboration with OMFIF on the implications of Brexit for the financial services industry. We had an excellent panel of experts representing banks and asset managers as well as the City of London in general. The event was badged as a 100 days post referendum […]
New York Department of Financial Services (DFS) has significantly raised the bar for cybersecurity programs, releasing regulations on September 13, 2016 slated to go into effect on January 1, 2017. The regulation will affect all entities with a DFS “license, registration, charter, certificate, permit, accreditation or similar authorization under the banking law, the insurance law […]
On August 25, 2016, the Securities and Exchange Commission (the “SEC” or the “Commission”) adopted amendments to various rules under the Investment Advisers Act of 1940 (the “Act”). The amendments will be effective 60 days after the date of publication in the Federal Register, but investment advisers are expected to comply with the amendments after […]
Saturday 1 October marked the 100th day since the result of the UK referendum to leave the European Union became known. And it seems neither the British nor their European neighbours have fully come to terms with the idea of a European Union without the UK. Yes, all continental Europeans love British eccentricity: driving “on […]
Following the UK’s landmark referendum decision to leave the European Union, real estate investors have been dealing with the push and pull of post-Brexit market sentiment. Initial panic surrounding the outcome of the vote saw a raft of UK-based fund managers suspend redemptions from property funds worth £18bn[1] as investors looked to exit the asset […]
In the second of our blogs looking at how the UK’s decision to exit the EU is impacting key real estate locations, our experts shine a light on some of the challenges facing German real estate investors, as well as the potential for greater breadth and depth of real estate opportunities going forward. Berlin: Strong […]
In the third of our blogs looking at how the UK’s decision to exit the EU is impacting key real estate locations, our experts outline some important post-Brexit political and practical considerations for French real estate investors. Need for visibility as political issues take centre stage It’s looking increasingly unlikely that real estate investors will […]
In the fourth of our blogs looking at how the UK’s decision to exit the EU is impacting key real estate locations, our experts in the US outline how the current lack of clarity opens the door of opportunity for investors who currently have capital to deploy. Uncertainty also brings opportunity for real estate investors […]
Following the UK’s landmark referendum decision to leave the European Union, real estate investors have been dealing with the push and pull of post-Brexit market sentiment. Initial panic surrounding the outcome of the vote saw a raft of UK-based fund managers suspend redemptions from property funds worth £18bn[1] as investors looked to exit the asset […]
“Blockchain is a bit like gluten. Everyone is talking about it, but no one knows what it is,” said Tim Swanson, head of research at R3, the financial technology innovation firm that is leading a consortium partnership working on blockchain to develop industry-wide common practices and standards, architecture models and specific transaction systems for use […]
At a time when the European Banking Authority’s stress tests have provided valuable insights into the solvency levels of European banks, these banks are continuing their efforts to formalise the conceptual and operational framework of risk management. While changes in capital requirements (the Basel Pillar 1 quantitative requirements) still command the attention of bankers and […]
Brexit continues to be omnipresent. From British Airways’ Business Life (September 2016 p. 11-12, “Post Brexit, Brand Britain must show its mettle… and its sense of humour”) to the Spectator, articles are a mixed cocktail of seeing Britain great again to worries about what’s next. It really depends on the lens through which you are […]
Over a beer with David Cameron in October last year, Chinese leader Xi Jinping expressed a very clear opinion on which way he wanted Britain’s vote on Brexit. He wanted a “prosperous Europe and a united EU” with the UK firmly in the EU. Britain certainly reached out to China during the last period of […]
Greece’s financial systems have been tightly monitored by the institutions – once called the Troika – of ECB, IMF and EU Commission in recent years. The systemically relevant Greek banks are under close control of the Joint Supervisory Team (JST), consisting of staff from the European Central Bank and members of the Bank of Greece, […]
Cyber attacks aren’t just getting more frequent, they are also becoming significantly more vicious and sophisticated. According to the latest figures from the Ponemon Institute, the average cost of a data breach has reached nearly $6.5 million in the US, alone. Yet today’s cyber attacks have far-reaching negative impacts that continue to ripple outward long […]
Thanks to Advanced Analytics, insurance providers can bring claims management into a new era by combining automatic processing of large volumes of data with human expertise. Analyzing data in order to optimize the claims processing chain is not a new phenomenon for insurance providers, notably in the field of health care. The health care sector […]
Recently released guidelines require institutions to adopt risk-based programs to monitor and filter transactions for potentially suspicious activity. Beginning January 1, 2017, financial institutions registered under the New York banking law are responsible for complying with anti-terrorism transaction monitoring and filtering program regulations, established by the New York Department of Financial Services (NYDFS). Last month, […]
The impact of Brexit on foreign banks, and especially the larger ones, has already been the subject of extensive media coverage and speculation. Discussions on the advantages and disadvantages of Brexit for larger overseas banks have been wide-ranging. Will the uncertainty over business models be solved in the short or mid-term? Would relocation bring cost […]
In previous weeks, I have commented mostly on early signs and emerging risks in the banking sector, including some early warning shots in the property space in particular. But banks and funds invest in many other types of assets and one sector – infrastructure and energy – may even be feeling some benefits from Brexit. […]
The Brexit debate last week was overshadowed by Theresa May becoming the UK’s new Prime Minister and some of her more radical appointments to her Cabinet. On top came the horrific terror attack in Nice and the failed coup d’état in Turkey. Understandably, the core Brexit debate did not take centre stage but instead provided […]
Brexit continues to dominate the political and financial world across Europe and beyond as people wrestle with its impact. But there’s another massive storm on the horizon for the EU that has been brewing for some time and Brexit may well have brought forward its impact: The Italian Banking Crisis. As reported in the Wall […]
As implied in the BCBS consultative document on November 2015, the BCBS published new standards on 11 July 2016 to include amendments on STC securitisations and thus make its final decision for their calibration. The securitisation framework was highlighted in the 2008 financial crisis because of the major role of subprimes in the collapse of […]
Confronted with legislation that is becoming increasingly constrictive, banks must optimize the management of their data. It’s a challenge that is compounded by the fact that data is often dispersed throughout information systems – a fact that aggregators are capitalising on to offer new multi-bank applications. Banks have a role to play in detecting abnormal […]
It’s two weeks since the Brexit Referendum and it’s fair to say that its consequences are already being felt. At a broad economic level, sterling has hit a 31 year low and economists have revised down the economic outlook for the UK and the Eurozone. The UK has been downgraded by Standards & Poor to […]
The Federal Reserve disclosed the results of its annual supervisory stress tests and CCAR (Comprehensive Capital Analysis and Review) respectively on 23 and 29 June 2016. In a combined exercise which has been running since the financial crisis, 33 US Bank Holding Companies (BHCs) were tested, including US-based banks and the American units of big […]
Basel 4 and Single Supervisory Mechanism act to reduce the excessive variability in the results of internal model approaches to credit risk. For more than ten years, Basel reform has encouraged the development and use of internal models designed to better place risk management at the heart of banks’ control arrangements. Basel II saw massive banking […]
Business funding diversification, helping to increase options for savers and making the economy more resilient are some of the main objectives set out in the European Commission’s Action Plan on Building a Capital Markets Union (CMU) published on 30 September 2015. While a better spread of financing sources over the capital markets, insurers, households and […]
As part of the content program on digital finance that Mazars has launched in partnership with the Economist Intelligence Unit, we are exploring in a new article on how mobile money is driving Africa’s cashless future. Over the last few years, Africa has become a global leader in mobile money with the rate of smartphone […]
Over the last decade, Africa has become a global leader in mobile money. The statistics for the use of smartphones as a payment mechanism are compelling with M-Pesa, in particular, by far the continent’s biggest mobile money triumph. Backed by UK-based Vodafone and launched in 2007 in Kenya by mobile network operator Safaricom, by 2015 […]
On 6 April 2016, the Basel Committee published a new consultative document outlining revision plans for the calculation of the leverage ratio and submit proposals for additional requirements applicable to systemically important banks (G-SIBs). This new consultation comes as no surprise. Since 2014 the leverage ratio, calculated by dividing Tier 1 capital by the bank’s […]
Banks prepare for the reinforcement of prudential supervision via the Single Supervisory Mechanism (SSM). After successive waves of new regulatory requirements in recent years, the outlook for the calculation of risks and Pillar 1 capital requirements is becoming clearer. At the same time, whereas the implementation of these new requirements has and continues to mobilise […]
At the same time as regulators as a whole express their support for the harmonisation, transparency and comparability of banking models at the European level, a new consultative document published by the Basel Committee on 24 March 2016 partly calls into question the use of internal model approaches when evaluating credit risk. The release of […]
The revised Payment Services Directive (PSD2) that comes into force in January 2018 will essentially remove many of the barriers to new players looking to enter the payments market by providing access to customer data and accounts through an EEA wide common legislative platform. Already under pressure from regulatory change and increased competition PSD2 is […]
We recognise digitisation as an important topic for the financial services industry; for this reason, we have developed a content programme with the Economist Intelligence Unit that focuses on how Financial Services companies are adapting their risk and reporting procedures to the new digital environment. This unique programme of thought leadership examines the new challenges in […]
UK Banks are already gearing up for the introduction of the revised Payment Services Directive (PSD2) that comes into force in January 2018. By providing clear guidelines and regulations, the Directive essentially removes the barriers to new players and opens the doors to FinTechs bringing new products and services to the electronic payments market. While […]
A series of initiatives designed to help combat terrorism financing have put electronic payment cards in the spotlight due to the fact they guarantee anonymity in the use of small sums. Announced on 23 November 2015, these initiatives supplement the action plan for combatting the financing of the terrorism presented by the Minister on 18 […]
By 2025, The Wall Street Journal ([1]) estimated that Generation Y, also known as Millennials, would represent nearly half of the total active population in the world. The challenge for banks is to adapt their strategy to match Generation Y consumer habits and behaviours. Unlike previous generations, Millennials have the increased ability to choose between […]
The number of electronic money players in the European market has increased in recent years, from 4 in 2010 up to 48 in 2014*. Add to this the fact that numerous players beyond the banking world have also created their own electronic money institutions, including Leetchi, Google and Amazon and the sector is now seen […]
Since the 2008 crisis, the financial sector has been under scrutiny. Identified as one of the crisis root causes, the importance of risk management framework and risk culture and its interconnectedness to ensure the long run financial stability of each organisation has been revealed. Accordingly, institutions are expected to develop an effective risk management framework […]
Financial Technology (“Fintech”) companies have kick-started a revolution in the payments landscape. Using state-of-the art technology, fintech companies are transforming how payments are transacted and processed. Banks and traditional payment providers are having to entirely rethink their approach to how they interact with innovations in order to stay on top of their game. Technological change […]
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To be a ‘good bank’, a bank must be efficient, innovative and trustworthy. Given its central role at the heart of the economy and financial system and the risks associated with fulfilling its role, banks have to operate within an environment subject to laws, regulations and directives. Outcomes can often be subject to the constraints […]
The last five years have been a time of much challenge and change for the Central Banking Fraternity in Europe. Crisis, both economic and political, has been followed by much adjustment and change, including both practical economic and policy interventions, structural change in the form of Banking Union, much new regulation and most recently the […]
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