We explore the key challenges organisations face in assessing fair value and outline practical steps financial services firms can take to meet regulatory expectations more effectively.
We outline a high-level approach for firms to consider when seeking assurance that governance, controls, and processes meet the expectations of the FCA’s proposed Motor Finance Redress Scheme.
Following the September 2024 FCA consultation paper (CP24/20) on proposed changes to Safeguarding rules, the FCA has recently issued CASS 15 outlining the new Safeguarding rules effective from 7 May 2026. We provide an overview of the new requirements, immediate actions and key considerations for firms to achieve compliance.
The FCA has launched a six-week consultation on a proposed redress scheme for Motor Finance commission arrangements, aiming to resolve longstanding concerns, provide clarity for consumers, and guide lenders through a structured path to compensation and compliance.
We look at some less obvious risks and assurance themes to help shape your planning for the year ahead, plus reflections on what stood out last year.
On 1 August 2025, the Supreme Court delivered its judgment in the three cases concerning the partial or non-disclosure of commission arrangements in motor finance agreements.
The Prudential Regulation Authority (PRA) initiated a major discussion on reforming the Internal Ratings Based (IRB) approach for residential mortgages with a paper released on 31 July. This Discussion Paper (DP) sets out the PRA’s preliminary considerations, and seeks feedback and supporting evidence, on a range of possible policy changes to the treatment of residential mortgage exposures under the...
On Sunday, 3 August, the Financial Conduct Authority (FCA) announced that it will consult on a redress scheme to secure compensation of up to £18 billion to affected consumers [1]. This follows the Supreme Court's ruling on 1 August 2025 [2], which largely overturned the Court of Appeal’s decision [3] regarding undisclosed commission payments in motor finance agreements.
The Financial Conduct Authority (FCA) has published its Consultation Paper CP25/23, setting out plans to regulate Deferred Payment Credit (DPC) - a fast-growing form of interest-free borrowing commonly associated with Buy Now Pay Later (BNPL) services.
In the wake of President Trump’s sweeping tariffs announced on ‘Liberation Day’, we explore the trajectory of the trade war since early April and assess how banks should interpret the latest macro and sectoral signals in their IFRS 9 frameworks.
Nearly two years since its implementation, the Consumer Duty continues to attract a mix of praise and criticism.
Geopolitical tensions and widening UK–EU–US regulatory divergences are reshaping the global financial landscape. Banks must now navigate rising compliance costs, strategic uncertainty, and fragmented supervisory oversight whilst balancing competitiveness and resilience.
As European banks move into 2025 amid renewed U.S. tariffs and heightened geopolitical tensions, is this calm before the storm? Throughout 2024, we observed a continued reduction in credit risk buffers, despite persistent macroeconomic pressures and geopolitical challenges. As we examine the year-end results of the region’s largest institutions, what do the figures reveal about how they manage expected...
As climate-related financial risks become more prominent, regulatory expectations and stakeholder demands are pushing firms to integrate climate risk into their risk management frameworks. However, a one-size-fits-all approach is neither practical nor effective.
Major changes are on the horizon for the Buy-Now, Pay-Later (BNPL) landscape following the publication of a Consultation Paper on the first-ever BNPL regulations by His Majesty’s Treasury (HMT).
As climate-related risks continue to reshape the financial landscape, institutions are under increasing pressure to integrate robust climate scenario analysis (CSA) into their risk management and strategic planning frameworks. Firms need to meet regulatory expectations, adopt best-in-class methodologies, and embed climate risk into core decision-making processes.
The proposals mark a fundamental shift in the application of consumer credit regulation, thus requiring firms to rethink their current approach.
Our webinar covers everything you need to consider following the release of the first consulting paper (CP 10/25) for the SS3/19 updates.
Following the recent FCA announcement on the potential outcome of its Motor Finance review, the new implications arising from the Court of Appeal judgment and insights from past remediation exercises, motor finance lenders should proactively consider the necessary steps to prepare to address concerns raised in the FCA’s review of discretionary commission arrangements and any further developments stemming...
In an increasingly complex and fast-paced environment, financial services leaders are focusing their efforts on strategic transformation, operational resilience and workforce readiness. Drawing on insights from executives across more than 35 countries, our latest report reveals how organisations in the sector are adapting to ongoing disruption, balancing risk with innovation and refining their long-term...
With the release of CP10/25, the PRA sets higher expectations for financial services companies’ approaches to managing climate-related risks.
The Prudential Regulation Authority (PRA) published its 2025/26 Business Plan on 10 April 2025, outlining how it will deliver its strategic priorities and continue to be an efficient and effective regulator.
The United States has intensified its tariff policies, sparking renewed global trade conflicts. These actions have introduced significant market volatility and heightened economic uncertainty worldwide.
In the first quarter of 2025, our experts commented on a number of announced regulatory developments. Our quarterly financial services regulatory newsletter is a comprehensive overview of topics relevant to firms that operate in the UK across all financial services sectors.
Confidence among UK financial services business leaders’ readiness for Artificial Intelligence (AI) and their actual plans for effective implementation are mismatched, according to our Performance Pulse survey.
The spotlight is now firmly on the 31 March 2025 deadline for firms to ensure compliance to the Operational Resilience regime, a pivotal moment that will test the sector's preparedness to withstand severe operational disruptions.
Chief Risk Officers (CROs) need to grapple with an increasingly complex risk universe, both in terms of the number and interrelated nature of risks. This results in a myriad of challenges, opportunities, and shifting priorities.
Fraud continues to be a significant challenge for businesses in the UK, resulting in billions of pounds lost annually to fraudulent activities.
The main story of the Small Domestic Deposit Taker (SDDT) Regime Pillar 2A proposals set out in CP7/24 is the simplification of the capital regime. This is particularly true for credit risk, credit concentration risk and operational risk. Below are some of the key details you should know.
In the past few weeks, the US president has kept financial markets and business leaders on their toes. With a surge of incoming information, analysts and investment managers know that systemic risks are rising, but how best can they navigate these changes?
Supervisory Statement SS3/19 sets out expectations for how UK (re)insurance firms, banks, building societies, and PRA-designated investment firms should manage and disclose financial risks related to climate change.
There have been significant advancements in climate science, risk management practices, disclosure frameworks, and scenario analysis since the latest publication of Supervisory Statement 3/19 [1] (SS3/19). We will review the current SS3/19 content in detail, focusing on governance, scenario analysis, risk management, and disclosure requirements as outlined in the April 2019 SS3/19.
We’ve measured the AI preparedness of over 300 businesses in the UK. Find out the results.
This past week was predictably eventful, and the upcoming week promises to be even more so. The US President continued his reshaping of both the American and global economy, imposing 25% tariffs on Mexico and Canada and an additional 10% on China beginning on 1 February, promising that Europe is next.
Looking ahead in 2025, there are obvious challenges to the global trade environment, whilst above-target inflation and the resulting elevated interest rates add further grit to the wheels of the global economy at a time when equity valuations are looking a little expensive. At the same time, acute recessionary and inflationary risks have diminished, meaning we remain essentially neutral in terms of...
Donald Trump officially became President of the United States of America for the second time. In the last few days, we have heard a lot about the new President’s plans: a precipitous hike in tariffs, deregulation in the bank, tech, energy and pharma sectors, reducing corporate taxes, a “cultural revolution”, ending global strife, rewriting global borders, ending illegal immigration… and so much more.
The Operational Resilience Regime in the UK aims to enhance the ability of financial services firms to withstand and recover from disruptions, ensuring critical services remain available. The goal is to protect consumers, market integrity, and overall financial stability by making firms more resilient.
In the fourth quarter of 2024, our experts commented on a number of announced regulatory developments. Our quarterly financial services S regulatory newsletter is a comprehensive overview of topics relevant to firms that operate in the UK across all financial services sectors.
On 4 November 2024 our Risk Management and Digital and Artificial Intelligence (AI) Advisory experts held a live Q&A webinar. Here is a summary of what we discussed around AI.
On 4 November 2024, our risk management and digital and artificial intelligence (AI) advisory experts held a live Q&A webinar. Here is a summary of the current CRO challenges.
The Prudential Regulation Authority (PRA) has released its Consultation Paper 14/24 (CP14/24), which includes significant proposals to enhance the UK’s large exposures framework.
We have identified the key risk areas for financial services business leaders in 2025. These risks have been prioritised based on their severity and the urgency of mitigation, informed by comprehensive market research, regulatory insights, and our assessment of the current challenges faced by these firms. We also highlight the changes in risk rankings compared to last year.
The plan explains how the Prudential Regulation Authority (PRA) will deliver its strategic priorities and continue to be an efficient and effective regulator.
On 15 November 2024, the Financial Conduct Authority (FCA) and the Financial Ombudsman Service (FOS) jointly issued a Call for Input (CFI) on modernising the redress system.
In PS6/23 and SS1/23 – ‘Model risk management principles for banks’, the PRA outlines five Principles designed to support effective model risk management. In this article, we outline the key elements of the third principle, model development, implementation and use.
In the economic outlook season, the key theme is policy uncertainty. Change will accelerate, some of it will be good and some of it will be a miss.
In the government's first Budget, Chancellor Rachel Reeves announced several measures that will impact the UK's Financial Services sector, and we examine here the impact of the policies announced.
Chancellor Rachel Reeves' Autumn Budget contained a sizeable increase in employers' national insurance contributions (NICs). This article examines how this will impact the Financial Services sector's tax cost and compliance requirements.
The most significant proposal stemming from the recently published CP7/24 is the introduction of a single capital buffer (SCB).
In the past few days, markets have been cheering at the prospect of deregulation, especially in the banking sector. The US election has become a catalyst for many government officials, across both sides of the Atlantic, to come out and advocate for deregulation. While upping economic and financial risk, it could be the key to unlocking economic growth in the years to come.
With differing approaches to Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) supervision across the EU, it has severely limited member countries’ ability to fight efficiently this growing threat. The creation of the Anti-Money Laundering and Countering the Financing of Terrorism Authority (AMLA) is a big step in addressing this issue.
Traditional methods of tackling financial crime are no longer effective in a world where bad actors use increasingly sophisticated techniques to exploit weaknesses in financial crime controls. With the establishment of a new European regulator, embedding the latest Artificial Intelligence (AI) enabled solutions to counter financial crime has never been more important.
Firms are expected to have a comprehensive Basel 3.1 implementation plan to support the quality of the upcoming data submissions and to ensure smooth operationalisation of the incoming regulatory regime. We encourage firms to focus on capital impact assessment, data governance and people and transformation priorities. Furthermore, it is imperative firms understand how Basel 3.1 fits within the wider...
The global economy is entering a more synchronized part of the cycle, but economies diverge.
Our experts provide an overview of current risk management challenges in Financial Services, as well as how to manage AI within risk management frameworks.
On 12 September 2024, the Prudential Regulation Authority (PRA) released the long-awaited near final rules for Basel 3.1 on Credit Risk, Output Floor, disclosures and regulatory reporting. As firms finalise their implementation plans, there are key submission dates they will need to work towards to ensure they are ready for Day 1 compliance on 1 January 2026.
In the third quarter of 2024, our experts commented on a number of announced regulatory developments. Our quarterly FS regulatory newsletter is a comprehensive overview of topics relevant to firms that operate in the UK across all Financial Services sectors.
Watch back on our Basel 3.1 webinar series, where our experts reflect on the Basel 3.1 final rules for Credit Risk and Output Floor, as well as what firms should prioritise from an operational perspective ahead of the implementation of Basel 3.1. This follows the publication of the Prudential Regulation Authority’s Basel 3.1 Policy Statement (PS9/24) in September.
In July 2024, the Basel Committee on Banking Supervision (BCBS) finalised the targeted adjustments to its standard on interest rate risk in the banking book (IRRBB).
In SS1/23 Model Risk Management (MRM) principles, the purpose of the Governance principle is to ensure firms have strong governance oversight with a board that promotes an MRM culture from the top through setting clear model risk appetite and clear accountability for model risk management.
Following the release of the PRA’s capital proposals in September, our experts provided an overview of the SDDT regime. This included reviewing the capital, liquidity and disclosure requirements, with a focus on the former.
The Policy Statement (PS9/24) contains the long-anticipated near-final policy proposals for Credit Risk and Output Floor under the forthcoming Basel 3.1 framework. We have outlined the key points from this Policy Statement for firms.
The proposals for the capital requirements of the Bank of England’s SDDT Regime are finally here. We have outlined the key points from this Consultation Paper. Overall, we believe that the proposals would have noticeable benefits from a cost of compliance perspective. However, the impact on overall capital requirements is unlikely to materially change, with reductions in Pillar 2B buffers offset by...
As financial services organisations increasingly focus on digital transformation, having the right expertise and skillsets is critical. However, it’s not simply a question of human capital. It requires developing a talent strategy that recognises the profound impact technology will have across the organisation.
The role of artificial intelligence (AI) in financial services continues to exercise C-suite minds. Not least, how to balance AI’s benefits to enhance the customer experience and improve back-office operations with the ethical challenges that AI presents.
The financial services sector is increasingly looking to technology to help tackle the rising levels of regulation they face.
In Business School, they tell you about accounting, business valuations, business strategy, interest rate theory, asset management, economics, currency parities, valuing options, alpha, beta, delta, theta and so, so much more. What they don’t tell you is that real portfolio management largely consists of following and dissecting the word of central bankers. ‘Don’t Fight The Fed’ is a time-tested principle,...
When financial professionals discuss derivatives, they usually talk about futures, swaps, and options. However, Nivida’s price falling 7% after posting second-quarter results that were ahead of consensus estimates seems to have the markets talking in derivatives, in a very different way.
The near-final Basel 3.1 rules on Credit Risk and Output Floor are expected on 12 September 2024. Ahead of this, we think there are several areas of the Bank of England’s proposals firms should be looking out for when the final policy is published. We discuss some of these below.
The new Credit Value Adjustment (CVA) risk framework methodologies for calculating capital requirements will comprise of the Alternative Approach, the Basis Approach and the Standardised Approach.
One of the centrepieces of the revised Basel proposals is the updated Output Floor. The main aim of the Output Floor is to bring greater alignment between the capital requirements for the credit risk Standardised and Internal Models approaches.
Jackson Hole, Wyoming, is a valley in North America, wholly unremarkable in history for anything other than it was named by someone called Jackson who caught beavers. Yet once a year, when the US Federal Reserve meets there, the eyes of the economic and investment world are fixed on this tiny area in the Rocky Mountains.
In the last three weeks, global stocks have sold off, wiping out nearly $3tn or -4.5% of their global capitalisation, while global bonds have gained +3.5% by the close of Friday 2 August. Just this morning, Japanese stocks (which trade between 24:00 and 06:00 in UK hours) fell by -12.4%, the worst single-day drop since 1987.
John Buchan (1875-1940), First Baron Tweedsmuir, author of “The Thirty-Nine Steps” and General Governor of Canada once said: ''You think that a wall as solid as the earth separates civilization from barbarism. I tell you the division is a thread, a sheet of glass. A touch here, a push there and you bring back the reign of Saturn.''
Financial services organisations see digital transformation as a top priority. While the competitive landscape has been evolving following the arrival of digital-first challenger banks and fintech players, emerging technology and rising mobile service demands from tech-savvy consumers are now pushing traditional players to innovate, rethink business models and how to accelerate and scale their technology...
Optimism in the financial services sector is riding high. So why is the financial services sector so confident and what needs to happen to ensure growth aspirations remain on track?
Both the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) have highlighted Diversity and inclusion (D&I) as critical to their work on culture and governance. Benefits from D&I in the workplace include positive outcomes in risk management, good conduct, healthy working cultures and innovation.
In PS6/23 and SS1/23 – ‘Model risk management principles for banks’, the PRA outlines five Principles designed to support effective model risk management (MRM), the first of which relates to ‘model identification and model risk classification’.
The European Banking Authority (EBA) has published amendments outlining requirements for calculating Prudent Valuation Adjustments (PVA) on fair-valued financial instruments held by institutions.
With the introduction of the Strong & Simple (S&S) regime, UK banks will be predominantly categorised as under either the S&S regime or the Capital Requirement Regulation (CRR). For firms considering whether to apply to the S&S regime a thorough evaluation of the respective regulatory implications of either approach is required.
On November 27th, the Financial Conduct Authority (FCA) published a second and final report with further observations on how firms are implementing requirements on the Internal Capital Adequacy and Risk Assessment (ICARA) process and reporting under the Investment Firms Prudential Regime (IFPR).
Pending the release of the PRA’s Basel 3.1 final rules, our banking risk experts discuss the proposed changes to credit risk and output floor rules, as well as the near-final rules relating to market risk and operational risk.
The Prudential Regulatory Authority (PRA) has outlined its expectations for the preparation of regulatory returns in The Dear CEO Letter (DCEO), which focuses on the “Thematic findings on the reliability of regulatory reporting”. Dated the 10th of September 2021, the letter highlights the PRA’s expectations for banks to submit reliable and accurate regulatory returns, and for the regulatory reporting...
Banks are expected to have robust governance and controls processes for the production of their regulatory returns. In particular, the PRA outlined its expectation that banks should perform independent testing and validation of their regulatory returns to ensure they are reliable and accurate. With the PRA’s increasing focus on regulatory reporting demonstrated through SREP reviews and S166s reviews,...
The Prudential Regulation Authority (PRA) continues to emphasise the importance of the reliability and accuracy of regulatory data for banks and building societies. Data risk is named a main priority within the 2024 Dear CEO Letter and through the Transforming Data Collection initiative between the Bank of England and the Financial Conduct Authority.
The US unveiled its take on the BCBS Basel reforms on July 27th, 2023, calling it the “Basel III Endgame” (referred to as Basel 3.1 in the UK). This article outlines the key disparities between the US and UK approaches to implementing these reforms.
On 17 April 2024, the Bank of England (BoE) published an article with useful insights for financial institutions on using scenario analysis to measure climate-related financial risks.
The Prudential Regulation Authority (PRA) has established robust new requirements for solvent exit planning, requiring UK financial institutions to proactively prepare for an orderly and solvent market exit.
Does the perceived reduction in risk amongst European banks hint at early signs of optimism for the sector? Throughout 2023, we observed a global economic slowdown, ongoing geopolitical tensions, and the rapid rise of new technologies. As we analyse the year-end results of the 26 largest banks in Europe, what do these figures reveal about expected credit losses and how these institutions manage persistent...
Recent modifications to the banking surcharge rules and the UK corporation tax main rate mean larger banks now face a combined tax rate of 28%, while many moderately sized banks may drop out of banking surcharge due to the increased £100m surcharge allowance available from 1 April 2023.
Overall, firms weathered the initial turmoil of the Covid-19 pandemic reasonably well thanks to a combination of deployment of technology to provide flexibility in remote working, and, in the case of banks, balance sheets which have been substantially bolstered in the aftermath of the financial crisis.
On Wednesday 20 July 2022, the government released draft legislation for the Finance Bill for 2022 and the results of consultations. We were expecting more draft legislation but there are some HMRC recommendations that cannot currently be signed off by ministers until we have a more stable government.
08 December 2021 This article delves into the interest deductions for foreign banks operating in the UK, outlining the background of the Capital Attribution Tax Adjustment, the five critical steps involved, and some helpful FAQs.
Peering into the crystal ball, we wonder - how much corporate tax banks in the UK are going to have to pay after 1 April 2023? On that day, marking the first rate rise since 1974, the corporation tax rate goes up, from its current rate of 19% to the new rate of 25%.
This edition of our newsletter summarises a selection of developments from the UK and Europe and provides key updates on matters we have discussed throughout 2023.
There was a flurry of regulatory activity in the lead-up to the festive period. Final Basel 3.1 for Market Risk, Credit Risk, CVA and Counterparty Risk were published. The PRA also finalised its disclosure and liquidity requirements for the Strong and Simple regime. There were also significant publications relating to Diversity & Inclusion and the Remuneration regime.
The regulatory environment for UK banks continues to be incredibly fast paced, exemplified by the developments in Q3 2023.
A recent report from Immunefi suggested that cyberattacks targeting cryptoassets increased by 150% in Q3 2023 when compared to the same period in 2022.
In December 2020, the FCA detailed some of their proposals for the Investment Firm Prudential Regime (IFPR), which will come into effect in January 2022.
The Bank of England (the Bank) shared its latest thinking on climate-related risks and regulatory capital frameworks in a report released on March 13, 2023. The report elaborates on six key findings and identifies areas for future research and discussion. However, the Bank does not introduce any policy changes in response to the report. Instead, it suggests further analysis is needed before introducing...
The Climate Financial Risk Forum (CFRF) has shared a non-regulatory practitioner’s guide for banks and building societies on how to use scenario analysis to assess the financial impact of climate change and inform their strategy and business decisions.
The 2008 Global Financial Crisis revealed that major banks were in fact ‘too big to fail’. They had grown so large and complex that they needed state support given the unfathomable economic consequences of their collapse. As a result, financial regulators have introduced robust prudential measures to try to prevent such a crisis from happening again. A critical element of these post-crisis reforms...
The Bank of England formally engaged with the international financial community to discuss the role of regulatory capital in the management of climate risks.
The Prudential Regulation Authority (PRA) has distributed a Dear CEO letter to all international banks and deposit takers active in the UK. This letter is to ensure there is a continuous focus guided by the PRA’s supervision and highlight the PRA’s planned work for next year; and should be read in conjunction with the feedback from individual PSM letters.
For many years, the PRA has been applying a proportional approach to both regulating and supervising smaller banks, but there is a marked difference as supervision has been more pronounced.
On 13 January 2022, the Payment Services Regulator (PSR) published its first formal strategy. The implementation of this five-year strategy will materially impact Payment Service Providers (PSPs) through increased focus on accessibility, protection, and competition.
The end of 2021 saw the PRA deliver on its warning in the September 2021 ‘Dear CEO’ letter, that they would take a tough stance on banks and building societies that fail to meet expectations around reliable regulatory reporting.
On 1 January 2022, the PRA’s Policy Statement PS22/21 'Implementation of Basel Standards' took effect.
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