11th October 2016

BBA comments to PRA CP 25/16: The implementation of ring-fencing: reporting and residual matters

The consultation paper (CP) is the third of a series of three and represents an important step in the completion of the regulatory regime in which ring-fenced banks (RFBs) will operate. As the PRA recognises, ring-fencing involves a highly complex business reorganisation and ties into other regulatory initiatives, not least on recovery and resolution and operational continuity.

If banks are to make an orderly transition to their new ring-fenced structures before the statutory deadline of 1 January 2019, then there are important steps that need to be taken in 2017 and 2018. We therefore appreciate the publication of the third CP within the planned timetable and the publication of Policy Statement 20/16 ‘The implementation of ring-fencing: prudential requirements, intragroup arrangements and the use of financial market infrastructures’ (PS20/16) and the appendices setting out the final rules and supervisory statements implementing the proposals consulted upon in CP 37/15 and also as related in Policy Statement 10/15 on legal structure, governance and the continuity of services and facilities.

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