They fuel our growth.
Everything that’s going on
in our company right now,
started as someone’s bright idea.
They fuel our growth.
Everything that’s going on
in our company right now,
started as someone’s bright idea.
They fuel our growth.
Everything that’s going on
in our company right now,
started as someone’s bright idea.
Capital Efficiency in Credit Risk
There is a perfect storm of demands on bank credit risk functions today.
In a low interest rate environment, with competition from an array of new credit providers, demands on risk from the business are growing by the day. Advanced risk models are sought to optimise RWAs and capital allocation. Timely, dynamic and insightful analytics and reporting is needed to drive pricing and strategy. And all of this must be done more efficiently and at low cost.
Financial Crime and Conduct: When controls collide
PPI mis-selling, market manipulation and Russian laundromats. The numerous high-profile incidents in financial services over the past 20 years have cast a dark shadow over the industry. Whilst damage to consumer trust and reputation has been long-lasting, the financial and criminal implications of regulatory action has also damaged shareholder value.
A challenging landscape calls for an evolution of the credit risk function
A bank’s bread and butter of generating high returns and increasing profitability is proving difficult in the current economic environment. At the same time as revenues are being challenged by low interest rates there is growing competition from new entrants and stringent capital and liquidity requirements. The business demands upon credit risk functions are increasing.
It’s not too late to succeed with SMCR’
With almost 50,000 firms going live with Senior Managers & Certification Regime (SMCR), the BCS Consulting SMCR team has been extremely busy supporting a range of clients, particularly within the CCA lending and asset management sectors. We are uniquely positioned based on our extensive experience and the insights we have gained from running the regime in business as usual (BAU) for almost a year in one of the largest global banks.
Activity Based Costing (ABC): Easy as 123?
Banks have had a tough decade. With deflated interest rates, ballooning compliance costs, and growing geo-political tensions, it’s no surprise that returns in the banking industry have not sprung back to pre-2008 peaks.
Financial performance in 2018 was particularly glum for European banks. Declining revenues contributed to low returns, reflected by share prices falling an average of 25% year on year.
Blockchain in Finance: Without better governance, it’s not going anywhere
In recent years, distributed ledger (‘blockchain’) technology has shifted from being a niche concept in computer science, to a mainstream topic in financial services innovation.
Born as the underlying technology for crypto-currencies such as Bitcoin, blockchain has since gained widespread interest in its wider applications. The
financial services industry, in particular, is now at the forefront of investment in adapting blockchain for general business use.
The trouble with Big Data: Measuring what matters
Data is undeniably ubiquitous. It underpins every transaction, operation and interaction within Financial Services today.
For the past 10 years we have been on the cusp of the big data enlightenment era, where capturing, managing and gaining business insights from data leads to customer-centric products and performance that sky rockets. So why haven’t Big Banks been able to fully capitalize on this so far, and what direction should they be going in?
What’s in a name? From LIBOR to SONIA?
Arguably, one number matters more than any other in the world of finance. It is the basis for huge corporate loans and it underpins nearly $200 trillion of derivative contracts. However, it looks to be on its way out and The City isn’t quite sure how to replace it.
The number in question is LIBOR – the London Interbank Offered Rate – an array of interest rates set daily by a group of banks. They are never linked to actual transactions, instead providing indicative rates. Significantly reduced volumes of unsecured term borrowing between banks, which is the basis for LIBOR, has called into question its ability to continue playing a central role.
Banks: Stop saying “yes” to the cloud with folded arms
Fifty years since Canadian engineer Douglas Parkill first hypothesised the widespread use of cloud-based IT services, we are still waiting for cloud computing to truly revolutionise the financial services industry. Security, data privacy and compliance concerns have weakened business cases to the extent that banks have often overlooked cloud technology as a major industry disruptor.
Project Management: Back to the Future
The current decade has been a relatively retrospective one, with a growing number of financial services professionals employed by change programmes aiming to right the wrongs of the past (e.g. product mis-selling remediation, implementing trade and transaction reporting enhancements, and / or clearing and collateral management requirements).
Failure planning: linking plans to performance
Banks’ reported results and investor guidance in recent years don’t make for pleasant reading. Most show us that banks have failed to hit their targets. The consequences can be broad and swift: stock price falls, reputational damage to the bank’s C-suite and a demotivating message to staff.
Pay it your way: Why payments innovation is needed
The humble payment that moves value from A to B takes many forms. Innovation in the sector is booming: in recent years the payments industry has seen the highest number of FinTech entrants – and largest proportion of investment in FinTech - of any banking sector. The push for real-time and mobile payments is a dominant theme, with over 40% of payment companies partnering with FinTech companies last year. Payments is among the most disrupted domains in banking.
Core Banking systems hint at why banks find Agile a challenge
This is a natural reaction from Chief Technology Officers and others across our many banking clients. Understandably so: as their name implies, core banking platforms are central to the operations of most banks, powering basic processes such as cash management which customers rely upon as part of their day-to-day banking service. Accordingly, banks approach changes to their core banking systems with great caution. Updates are infrequent and require meticulous planning; outright replacement is only considered out of necessity – generally, once the functionality has lagged so far behind a bank's operational needs that it constrains or threatens the provision of customer services. As a result, many such systems in use today were built on mainframe technologies that are now decades behind the state of the art.
Is this the end of PMO?
For projects big and small, an effective PMO (Project Management Office) is integral to its success and has an undeniable influence over the culture in which it operates. As a function, an effective PMO represents the eyes and ears of the programme, ensuring key messages are highlighted correctly in governance meetings, areas of concern are escalated effectively and ultimately provides management with the necessary level of control which is so regularly missing from a given change initiative.
Open Banking: How to realise the benefit for mortgages
Prove who you are, what you earn, and your source of funds. A bank is only one part of the house-buying journey, and it’s not the fun part. Mortgage applications are typically lengthy and time consuming, eating into a customer’s most valuable asset: time.
Open Banking provides banks the opportunity to give customers some of those precious hours back, whilst satisfying their credit risk, fraud and regulatory requirements. This new technology encourages competition, empowering customers to shop around with their transaction data; potentially to be used by third parties and banks to offer better deals.
Cloud: Banks won’t benefit until they embrace Agile
As our banking clients look to expand their IT estate to the public cloud, we are finding them increasingly aware of the real benefit of doing so: rather than purely a cost play, cloud is an agility enabler of fundamental relevance to the digital agenda. However, without the adoption of Agile ways of working at the grassroots level, banks may gain nothing from cloud to help them compete in the digital age.
Open Banking – Embracing the new banking paradigm
Customer-centricity is a term that has been around banking for years. However, the flood of new entrants into the banking market is a tell-tale sign of an old problem; major banks are still not addressing customers’ needs and building trusting relationships. The gap between customer expectations and banks’ responses to how banking services should be provided has continued to widen. This is exacerbated by the highly personalised experience customers are receiving from service providers in other industries. In addition, regulators have noticed that consumers are getting a bad deal and have intervened with Open Banking and PSD2; a clear indictment for all major players in the financial services market.
ESG reporting: Improving performance and perceptions
Environmental, Social and Governance (ESG) factors, which relate to ethical and sustainable practices, have recently risen to prominence within the financial industry. Led by the existential threat of climate change, financial crises and demographic shifts, investors have become acutely aware that ESG factors impact asset values.
Digital Distrust: Change Management in the AI era
The wide-scale adoption of Artificial Intelligence (AI) is accelerating in financial services, with firms already using AI for customer services chatbots, fraud detection, and trading to name but a few.
For banking executives who have struggled to restore profitability in the aftermath of the financial crisis, AI is a welcome ray of hope to achieve cost-reduction targets. Past CEOs of Deutsche Bank and Citigroup have publicly commented on the potential to replace 30-50% of the workforce with AI solutions.
Operational resilience: Preparing for failure
Over the last 10 years, regulators have focused on improving the financial resilience of banks. As a result, banks now hold more capital, along with more liquidity, than ever before – a measure that has significantly reduced the risk of any individual bank threatening the stability of the wider financial system.
Driving accountability within the 1LOD: The role of the Chief Control Officer (CCO)
Driving accountability with senior management is viewed by many as the most effective way to instil an effective risk management culture.
However, despite the introduction of the Senior Managers Regime and large investment in establishing industry-standard Three Lines of Defence (3LOD) models, losses continue to rise with the heat of accountability often only felt after the incident and management of non-financial risk still being viewed as a burden, rather than an enabler.
GDPR – Data strengthens its defences
The General Data Protection Regulation (GDPR) is an EU-wide initiative designed to strengthen individuals’ data rights by introducing tougher standardised data protection laws across all industries throughout the single market. The regulation aims to put us, as individuals, back in charge of our personal data and stop organisations having the ability to profit from this data without our knowledge or there being a legitimate legal reason. The regulation covers all EU personal data and will go live on 25th May 2018.
Senior Managers & Certification Regime
Senior Managers and Certification Regime (SMCR), or the Individual Accountability Regime (IAR) as we previously referred to it, consists of the Senior Managers Regime (SMR), Certification Regime and Conduct Rules and it came into play in March 2016 for banking entities.
PSD2 Payments – Share and share alike
To define PSD2, we need to revisit the scope of the first European Payments Service Directive (PSD) implemented back in 2009. The driving force behind both directives is harmonisation of the payments landscape to level the playing field amongst EEA countries, including payment service providers, with the end goal of increasing competitiveness, creating better value for consumers and, at the same time, reducing barriers to entry and expansion.
Are you on the SMCR hook? The challenges of identifying who is truly accountable
As financial institutions edge their way towards the extension of the Senior Managers & Certification Regime (SMCR) in late 2018 and 2019, two surprising questions are being overlooked: who will actually be the Senior Managers in each of the firms and what will they be truly accountable for? Defining these seem obvious, but many firms have overlooked some of the potential options and are striding off in the wrong direction.
SMCR transitional arrangements: don’t be one of the late starters!
In July 2018, the FCA and PRA published the latest set of policy statements and consultation papers on the extension of the Senior Managers and Certification Regime (SMCR) to insurers and FCA authorised firms under the Financial Services and Markets Act (FSMA). The publications provided near final rules, transitional arrangements and most significantly the go-live of 9th December 2019 (the insurance go-live of 10th December 2018 had already been announced). Although the proposed dates may, at first glance, appear to allow plenty of time to prepare, firms must seize the opportunity to learn from the mistakes of the banking implementation and begin planning for go-live today.
Back in the driving seat: How driver-based modelling can help restore profitability
Investors are starting to flex their muscles again in the Square Mile. It seems that an average Return on Equity (RoE) of 7% across Europe1 – below the typical cost of equity – is not enough to satisfy shareholders, as the calls to return to pre-crisis levels of profitability grow louder.
A prolonged period of low interest rates and increased capital requirements mean the days of RoEs over 20% are a distant memory. Nevertheless, banks are looking for ways to respond to investor pressure and improve returns. In this environment, understanding what drives returns, and the impact should they change, is key.
Using Third Parties: A competitive advantage or a cause for concern?
The risks incurred by Financial Services (FS) institutions' that employ third parties, to support delivery of their products and services, is a topic that the non-financial risk community have opined on for many years.
Outsourcing any activity to another firm potentially exposes organisations to all manner of delivery, conduct and reputational risks and impacts, but it is an operational necessity and a commercial reality that they cannot avoid.
Blockchain: we need to talk about governance
The booming speculative interest in cryptocurrencies during 2017 put a spotlight on the underlying technology that enables them: distributed ledgers, more commonly known as ‘blockchain’. Riding this wave of momentum, a number of sophisticated blockchain platforms have since emerged that, from a technical perspective, offer all the building blocks needed for credible enterprise-grade transaction solutions.
SFTR: Don’t wait for the starting gun
The industry is eagerly awaiting the European Commission to adopt the Regulatory Technical Standards for the Transaction Reporting component of the Securities Financing Transactions Regulation (SFTR), that will give investment firms one year to implement their solutions before go-live.
Whilst there’s been a temptation to wait for this starting pistol, there’s plenty of pre-race prep firms can be doing to secure resources, perform analysis, develop requirements and leverage current solutions.
Visualisation: Finance adding value, not adding up
Higher capital requirements, compressed returns, and the rising ‘culture of data’ mean Finance departments are under more pressure than ever to move from overhead to value-add.
In this environment, production of Finance MI is an area under particular scrutiny. Finance teams have historically churned out internal reports at the expense of great time and effort, only for consumers to often complain that MI is not sufficiently timely, relevant or understandable.
Machine Learning – An automotive analogy
Progress in emerging technologies, such as machine learning, is creating alternatives to labour intensive risk modelling activities. Banks will require vision, investment and enduring strategic actions to truly leverage the full range of potential benefits
The roadmap defined for autonomous electric cars by tech giants and cars manufacturers include: changes to usage and storage of fuel; investment in talent, tools and infrastructure; evolution of next generation maps and levels of automation; and the overcoming of regulatory challenges. Recent developments have sparked debates on the impact of the economy, infrastructure, and regulations.
Managing uncertainty with the Standardised Measurement Approach (SMA)
Compromise is not easy, as the Basel Committee found when they published the final Standardised Measurement Approach (SMA) for calculating operational risk Pillar 1 capital in December. As the name suggests, a fundamental intention of the SMA was to provide a global framework to further standardise the management of operational risk capital. Instead, following a period of industry consultation, the SMA appears to have created more uncertainty for financial institutions and will further hinder the comparability of cross-industry operational risk capital data following its implementation in 2022.
Open Banking, Interoperability, and the Bank of the Future
Consumers don’t really care about banking
The traditional methods of engaging with financial service providers, including banks and asset and wealth managers, are becoming out dated – they are boring customers.
However, one thing customers do care about is money; all they want to do is ensure that their money is being handled in the best possible way, with ease of service. Given this, some may say that interacting with a firm is a necessary evil; it’s the friction in the middle of this exchange.
s the ability for systems and organisations to work seamlessly together, based on common standards.
Open Banking – Think Customers, not Compliance
‘Open Banking’, the term used to describe the opening up of banking to non-banks by widening access to customer account information, and allowing third parties to initiate payments on a customer’s behalf, has frequently made the news over the past months. However, all too often news stories and bank announcements did not herald successes as banks underestimated the complexity and scale of Open Banking implementation, leading to slippages.
SFTR – Not just another EMIR
As we enter 2018, much of the Capital Marketregulatory focus is concentrated on the early days of MiFID II. The Securities Financing Transactions Regulation (SFTR) appears to have fallen off the industry’s radar, seemingly dismissed as EMIR’s younger sibling. However, there is much more to it than that, and failure to comply could mean significant regulatory fines. I’m of the opinion that, despite the challenges, SFTR represents an opportunity for firms to gain a competitive edge with strategic use of new data capabilities.
Beyond Open Banking Compliance – Doing a Bit Extra
Retail banking is at a crossroads. The implications of Open Banking on banks’ business models have been well-publicised, with plenty of talk of the increasing separation of products from distribution. Banks are deciding which parts of the value chain they’re going to target and, given the current uncertainty across the market, the likelihood is that they will try to pursue multiple strategies concurrently to take advantage of the opportunity.
How climate change could make or break banks’ bottom lines
A growing number of studies are showing that climate change could be disastrous for organisations around the world.
If global temperatures jump 4ºC by 2100 (the path we are currently on), droughts, flooding and ferocious storms may be sparked, with economic models estimating a reduction in value of the world’s financial assets by between $2.5tn and $24tn. Implications for financial services institutions could be monumental.
A New Mentality: AML and Open Banking
C$1.15 million £72 million $225 million £630 million $1.9 billion...what do these figures have in common?
This is just a handful of the fines which have been levied against banks over the last five years for mismanagement of financial crime; as a result, financial institutions have been taking the threat of financial crime much more seriously.
Controlling Risks Without Breaking the Bank
Control should add value… not cost.
In response to corporate scandals such as Enron, the Sarbanes Oxley Act 2002 (SOX) was enacted. Since the introduction of SOX and the financial crisis in 2007, regulators have sought to ensure that banks are operating safely on both an individual and systemic basis...
Supply Chain Finance for SMEs – The Hidden Opportunity
Supply Chain Finance – as a financing option for SMEs – is ripe for digital disruption.
Small and medium-sized enterprises (SMEs) – companies with fewer than 250 employees and annual turnover of less than £25m – are becoming ever more prevalent within global supply chains. Owing in part to increases in globalisation, digitalisation and consumer demand for bespoke products and services, SMEs are at the forefront of the global trade landscape.
What does SIBOS hold for DLT?
The agenda for this year's SIBOS has noticeably fewer DLT-related sessions than last year, and given much of the financial services commentary over the past 6 months, you might feel AI has overtaken DLT / blockchain as the topic of interest for the industry. Without doubt, the number of column inches written about DLT has tailed off and Gartner's latest Hype Cycle for Emerging technologies (July 2017) puts blockchain just past the peak of inflated expectations. Perhaps, after all, it's been decided that blockchain is just another fad that will disappear as quickly as it arrived?
GDPR and MiFID II: A car crash waiting to happen?
2018 is a big year for financial regulation, with the Markets in Financial Instruments Directive (MiFID II) and the General Data Protection Regulation (GDPR) both coming into force in the first six months. Both regulatory vehicles deal with data management, and both will have a significant impact on the way financial institutions operate. However, whilst MiFID II seeks to improve transparency by encouraging data gathering, retention, and sharing, GDPR mandates more stringent controls around the same activities.
Successful Project Delivery really starts at Go-Live
The Financial Services industry today is faced with ever increasing demands: customers expect services to be quicker and smarter, regulators are applying greater scrutiny and setting higher standards, employees expect more from their employers, and shareholders still expect regular dividends and a good return on their investment.
Could Brexit be Britain’s regulatory Trump card?
Regulation in Financial Services has been on a steady rise since the financial crisis. It becomes more detailed, intrusive and onerous by the day. Industry participants are pleading to the regulators to slow down and let things stabilise, but there is no sign of a slowdown yet.
Knowing your sources: Pillar 3 reporting and the role of data lineage
Data is the foundation of all regulatory reporting.
Across the full range of regulatory reporting requirements, banks must source information from many different systems, enrich and aggregate it at multiple points, and eventually produce reports that go to regulators and to the public.
Cyber risk: It’s everyone’s business
Cyber is the number one operational risk faced by banks and each year it increases its lead at the top of the ranking. The industry isn’t waiting to see if there will be another cyber-attack, but rather when and how bad.
Regulators are increasingly harsh on cyber breaches and the introduction of the General Data Protection Regulation in May 2018 could result in fines of up to 4% of global turnover if data is breached in a cyber-attack. In addition, recent high-profile cyber breaches have meant that customers’ trust in their bank, one of the key tenets of loyalty, is at risk.
Robotic Process Automation: A taste of the future or repeating the past?
Robotic Process Automation (RPA) is being lauded by some as the next major trend for transformation in Financial Services.
RPA involves deploying software that imitates a ‘real’ user by performing repetitive manual work across applications and systems, without the need for complex systems integration. ‘Robots’ interact with a user interface the same way a human would, have their own logins and are able to toggle between programs to perform tasks like copying and pasting data.
Conduct vs. profit: How will it end?
Over the last few years retail banks have implemented a series of changes, often at a significant cost, to improve their conduct towards customers. On the surface these changes appear to have been successful: the industry has seen a decrease in the volume of PPI complaints and fines issued by the FCA. Some firms might think that they can begin to ignore the focus on conduct and ‘get back to the business of improving profitability’.
Senior Managers Regime implementation: The reality
7th March2017 marked the first anniversary of the Individual Accountability Regime (IAR); consisting of the Senior Managers Regime (SMR), Certification Regime and Rules of Conduct. As the industry adjusts to the new normal and reality sets in, there continues to be a multitude of challenges faced by firms and regulators alike, including reasonable steps definition and documentation, enforcement action, population identification, and changes in the political landscape.
I’d like my data back please: implications of the EU General Data Protection Regulation
In a financial services industry which is increasingly technology and data-driven, banks need to consider the impact of the EU General Data Protection Regulation (GDPR) on the way they process personal data, and how they can demonstrate customer consent to do so. With fines for non-compliance of €20m or 4% of annual global turnover (whichever is larger) it is imperative institutions don’t fall short of GDPR requirements.
Risk & Finance alignment: it’s not just data
Over the years, alignment between Risk and Finance within banks has been a topic of much debate. Driven by both internal and external factors, it has led to vast sums in project spend. Some progress has certainly been made, but adequate alignment remains elusive.
Pull your SOX up – enhanced assurance for regulatory reporting is on the way
In the early 2000s a number of major corporate and accounting scandals such as Enron and WorldCom resulted in a major shake-up of financial reporting. The accuracy of publically reported financial information was put under increased scrutiny and the Sarbanes-Oxley Act (SOX), also known as the “Public Company Accounting Reform and Investor Protection Act” was introduced as a result.
Innovative thinking can overcome blockchain technology’s technical challenges
Already in 2017 we have seen the topic of distributed ledger technology (DLT) in financial services widely discussed, with the Depository Trust and Clearing Corporation (DTCC) the latest to commit to the technology. But as interest grows, the questions turn not just to the technology’s theoretical potential, but to its practicalities in financial services environments.
How will Dodd-Frank fare now Trump’s attention has turned to banks?
The Dodd-Frank Act, brought into law in 2010, created comprehensive reforms to both curtail excessive risk-taking in financial markets and increase consumer protection. It strengthened regulatory oversight of the swaps market, moved standardised derivatives onto regulated exchanges, and mandated centralised clearing. During his campaign, the now President Trump announced that he wants to dismantle it....
Switch bank? In the future you won’t have to
Imagine a world where it doesn’t really matter who provides your current account, your ISA or your mortgage, and yet you always get the best deals. Imagine if you had a single place to manage all your financial products, regardless of type or brand. Is this a financial fantasy?
Smart Contracts: Unlocking the power of blockchain technology
Alongside the meteoric rise in interest in Distributed Ledger Technology (DLT, “blockchain”) across the financial services industry, another term has entered the financial lexicon: smart contracts. The timing is not coincidental; DLT and smart contracts are inextricably linked. Smart contracts are essential to realising many of the benefits promised by DLT, whilst in turn depending on DLT’s consensus-generating capabilities.
Regulatory compliance, an educated guess
Widespread market reform following the financial crisis has left financial institutions scrabbling to comply with a myriad of regulations. An alarming feature of many of these regulations is the short time period between the finalisation of the rules and the implementation deadlines.
Tempering the blockchain hype
In our previous blog we provided some background as to why blockchain and distributed ledger technologies have generated such excitement in financial services, with multi-billion dollar per annum savings forecast for the industry. We believe there will significant benefits to the industry but there is a need to provide some counterbalance to the current hype, and be clear on the challenges the industry will face in adopting and implementing these technologies.
The final sprint for FRTB… are you prepared?
The Minimum Capital Requirements for Market Risk, also known as the Fundamental Review of the Trading Book (FRTB), is a revised market risk capital framework developed by the Basel Committee on Banking Supervision (BCBS), which was finalised in January 2016.
What is blockchain technology and why does the FS industry care so much?
Blockchain technology has been the talk of the financial services industry throughout 2016, and rightly so. Through our discussions with banks and industry leaders, and at industry events such as SIBOS, we can see that the potential of the technology is clear, justifying the excitement and fervour.
MiFID II: what does it mean for the buy-side?
The industry is closing the year with significantly more clarity on the MiFID II rules than it started with, however, uncertainty remains in a number of areas that particularly affect the buy-side. With the January 2018 deadline just over twelve months away, buy-side firms must continue to plan for the multitude of changes needed to ensure regulatory compliance.
The rising of the ISIN
For several months an industry working group, spearheaded by ANNA, ISO and ISDA, has been grappling with the challenge of defining a methodology and creating a system that will enable the real-time creation and distribution of International Securities Identification Numbers (ISINs) for OTC derivatives, primarily to support MiFID II rules.
Could blockchain solve the KYC/AML challenge?
With the advent and evolution of new technologies such as distributed ledger technology (DLT) and Artificial Intelligence (AI), many opportunities are arising for banks to reduce their IT and operational costs through mutualisation or automation of their non-differentiating processes.
All Clear for Euro Clearing?
EU bureaucracy was cited by many as a key driver of the Brexit vote. It is ironic then that, following the ‘Leave’ vote, the complexity of the EU machine is perhaps all that shields the City of London from the loss of its Euro denominated clearing business, worth an estimated €600bn - €1tn per year.
The Systematic Internaliser Challenge
Irrespective of other uncertainties in financial markets post the British EU Referendum, one thing will remain firmly on the agendas of investment firms. With MiFID II set to go live on 3rd Jan 2018, firms must begin to grapple with the complex solutions required to solve the systematic internaliser (SI) challenge.
Not every data problem is a ‘Big’ Data problem
Both regulators and senior management expect banks to get more from their data. The range of information available from both internal and external environments has grown dramatically in recent years, presenting unprecedented opportunities for quantitative risk assessment and decision-making.
Senior Managers Regime: It’s time to get implementing
Ever since the FCA and PRA published their first joint consultation paper in July 2014, the regime has attracted a huge amount of boardroom attention. For individuals who fall within the Senior Managers Regime, this is absolutely understandable given the significance of what the regime is trying to achieve and the change in behaviour and rigour that it requires.