2nd May 2017

Chief Executive newsletter – May 2017

Written by Anthony Browne

Welcome to my newsletter. Despite the various bank holidays, it’s been a busy period, with elections at home and across the Channel dominating the political and media agenda.  The snap General Election announcement following the Easter holiday was certainly a surprise. While purdah has commenced we are continuing to focus our activity with ongoing engagement with policymakers across the EU.  Throughout May myself and members of the BBA team will be in Malta, France, Germany and Brussels as we continue to meet with European businesses and policymakers to discuss the importance of securing an orderly transition and continued market access for banks operating across the EU.

EU Banking Package and Intermediate Parent undertaking

However, it is not just Brexit that we have been discussing over recent months. We continue to engage in Brussels on the European Commission’s proposals in CRD V that introduce a requirement for third country banks to create an EU intermediate parent undertaking (EU IPU). These include focussing the asset size test on banking assets only, by excluding investment firms that are not systemically important from the asset size test and removing the single EU IPU requirement to mitigate the conflict with structural requirements in some non-EU countries. As drafted, the proposals could significantly complicate the mechanism for bank resolution and we remain committed to helping policy-makers refine their proposals.

Response to FCA Mission Statement

Looking closer to home in Mid-April, the FCA published its Mission and Business Plan for the coming year. Designed to give firms and consumers ‘greater clarity’ about how the regulator prioritises its interventions in financial markets, we welcome it’s transparency and approach, which will no doubt provide a helpful benchmark. In our submission to the regulator earlier this year, we asked for a number of areas to be given consideration including, amongst others, a clear competition mandate, the need for clarity around the targeted application of regulation; through publicly accountable guiding principles that avoid retrospection, fairness and innovation to develop socially useful products as well as dynamic regulation that anticipates the pace of technological change. We look forward to considering the FCA’s more detailed papers that will help bring its mission statement to life and hopefully address some of these areas.

4th Anti-Money Laundering Directive

We are continuing to work with members and HMG on the Government’s Anti-Money Laundering Regulations to help ensure that the proposals effectively balance the management of risk with the need to support growth and for business and customers to access banking services. In particular we have focussed on how to support effective implementation of requirements on due diligence for correspondent relationships as well as the requirements on data retention of customer due diligence and transactions data.

On the Criminal Finances Bill we will continue close public private partnership work with HMG and law enforcement on implementation of the measures to more effectively share information and intelligence on organised crime and terrorist financing, as well as ensuring new powers to recover assets from criminals are used effectively.

UK Finance Update

I am delighted to write that Stephen Jones has now been confirmed as the first CEO of UK Finance, the new industry body representing UK finance and banking, which is due to launch this Summer. Stephen brings a wealth of experience and knowledge of the finance and banking sector and, as the inaugural chair of the BBA’s Finance and Risk Policy Committee, he is already familiar with the opportunities and challenges the industry faces. His appointment will ensure UK Finance continues to support customers, businesses and the country as a whole.

Towards the end of last month I announced that I would be leaving the BBA following five years at the helm as CEO. It’s been a busy few years to say the least and it has been a privilege to serve at the BBA during this time, and a pleasure to work with the excellent staff, the BBA Board, members and wider industry colleagues.

I am here until BBA activities are transferred to UK Finance in July, which offers a few more months for me to continue serving the organisation and its members and hopefully the opportunity to catch up with many of you before I leave.

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