Risk and Regulation Monthly - REGULATORY STRATEGY EMEA - Deloitte
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Contents CONTENTS HIGHLIGHTS COVID-19 BANKING CAPITAL MARKETS INVESTMENT MANAGEMENT CENTRAL BANK OF IRELAND OTHER CONTACTS Highlights COVID-19 and its economic impact continued to dominate the news agenda throughout April. At the European level, the ECB announced that it was changing its rules so that it will accept bonds that lose their investment-grade credit rating as collateral in exchange for cheap liquidity funding available to banks. Any bonds rated as investment grade on April 7 will continue to be eligible even if they are downgraded below the triple-B level by the main credit rating agencies as long as their rating remains no more than two notches below investment grade. However, these assets will be subjected to “haircuts” to reduce their value as collateral based on their latest credit rating. For a full list of COVID-19 related regulatory, monetary and fiscal policy initiatives, please see our report available here.
COVID-19 EU EBA Statement on supervisory reporting and Pillar 3 disclosures, share buy- backs and remuneration, and financial crime in the context of COVID-19 Guidelines on treatment of public and private moratoria in light of COVID-19 measures Guidance on supervisory flexibility in relation to COVID-19, covering market risk, SREP, operational resilience and recovery planning ECB - SSM Interview with Andrea Enria, Chair of the supervisory board of the ECB, on Bloomberg TV, regarding restrictions to European bank distributions Article by Andrea Enria, Chair of the supervisory board of the ECB, on how European banking supervision can help fight the economic consequences of the COVID-19 crisis in Europe Statement on measures to provide temporary relief for capital requirements for market risk Interview with Andrea Enria, Chair of the Supervisory Board of the ECB, with El Confidencial on supervisory measures in response to the COVID-19 crisis ECB Central Bank Statement supporting macroprudential policy actions taken in response to the COVID-19 crisis Communication on the collection of statistical information in the context of COVID-19 Statement on loosened collateral eligibility rules to mitigate the possible effect of ratings downgrades Statement on new pandemic emergency longer-term refinancing operations (PELTROs) Statement on revisions to targeted lending operations ECOFIN Report on the comprehensive economic policy response to the COVID-19 pandemic Statement of EU ministers of finance on continuing bank lending and on maintaining a well-functioning insurance sector Document containing a roadmap for recovery towards a more resilient, sustainable and fair Europe ESMA
Clarification of issues around publication of best execution reports under RTS 27 and 28 of MiFID II Risk assessment updated in light of the COVID-19 pandemic Statement on actions to mitigate the impact of COVID-19 on deadlines for the publication of periodic reports by fund managers Extension of MiFID II/MiFIR transparency review report consultation Postponement of publication dates for annual non-equity transparency calculations and quarterly systematic internaliser (SI) data Statement on actions to mitigate the impact of COVID-19 on the EU financial markets regarding external audit requirements for interest rate benchmarks under the BMR Issued opinions agreeing to the renewal of five emergency restrictions on short selling New Q&As on alternative performance measures (APM) in the context of COVID-19 SRB Letter to banks on potential operational relief measures related to COVID-19 Blog by Elke Konig, chair at the SRB, on the SRB's approach to MREL targets in light of the COVID-19 crisis Int’l BIS Measures to alleviate the impact of COVID-19 on global banking systems Speech by Mr Stefan Ingves, Governor of the Sveriges Riksbank, on the Riksbank's measures to mitigate the effects of the corona crisis on the economy Report on COVID-19, cash, and the future of payments Paper on the macroeconomic spillover effects of COVID-19 on the global economy Speech by Jerome H Powell, Chair of the Board of Governors of the Federal Reserve System, on COVID-19 and the economy Interview with Luis de Guindos, Vice-President of the ECB, on the COVID-19 crisis and the approach to recovery Interview with Christine Lagarde, President of the ECB, on responses and potential future measures to tackle the COVID-19 crisis Financial Stability Institute Brief No.1: Reflections on regulatory responses to the COVID-19 pandemic
Remarks by Ms Isabel Schnabel, Member of the Executive Board of the European Central Bank, on the corporate governance implications of COVID- 19 Research paper on COVID-19 and operational resilience: addressing financial institutions' operational challenges in a pandemic Speech by Benoit Coeuré, Head of the BIS Innovation Hub, on the value of resilience and technology in tackling the COVID-19 crisis Interview of Luis de Guindos, Vice-President, on the ECB's approach and response to the COVID-19 crisis Note on expected credit loss provisioning under a global pandemic Research paper on COVID-19 and corporate sector liquidity Paper on public guarantees for bank lending in response to the COVID-19 pandemic Leverage and margin spirals in fixed income markets during the COVID-19 crisis FSB FSB members take action to ensure continuity of critical financial services functions Report on financial stability implications and policy measures taken in response to COVID-19 FSB Sub-Saharan Africa group held a conference call to discuss regional financial stability and the impact of COVID-19 IMF Blog on global uncertainty related to COVID-19 reaching a record high Blog on "Cash buffers for a rainy day" to tackle COVID-19-related challenges Policy paper on enhancing the Emergency Financing Toolkit in relation to responding to COVID-19 Executive Board Approves Proposals to Enhance the Fund’s Emergency Financing Toolkit to US$100 Billion IMF Executive Board approves immediate debt service relief for 25 countries Blog post entitled "The Great Lockdown: Worst Economic Downturn Since the Great Depression" Blog on fiscal policies countries could employ to contain the damage from COVID-19 Blog on Economic Policies for the COVID-19 War
IOSCO Statement on Application of Accounting Standards during the COVID-19 Outbreak Reprioritised IOSCO work programme addressing impact of COVID-19 Back to top
Banking Prudential EU EBA Basel III monitoring report and report on liquidity coverage ratio compliance, based on end-June 2019 data Phase 1 of EBA technical package on reporting framework 2.10 Statement endorsing European Commission’s amendments to RTS on risk weights for specialised lending exposures Updated list of Other Systemically Important Institutions (O-SIIs) Risk dashboard for Q4 2019, covering Q4 2019 data and summarising the main risks and vulnerabilities in the EU banking sector ahead of the COVID- 19 crisis Updated Guidelines on equivalence of non-EU authorities for participation in supervisory colleges ECB Central Bank Euro area bank interest rate statistics for February 2020 published ECB – SSM Supervisory Banking Statistics for Q4 2019 Euro area bank lending survey Int’l BIS Report on global liquidity indicators at end-December 2019 Progress report on banks' implementation of its principles for effective risk data aggregation and reporting Working paper on equity price volatility spillovers and capital buffers among the G-SIBs BIS Bulletin No. 1: Dollar funding costs during the COVID-19 crisis through the lens of the FX swap market Basel III monitoring results based on end-June 2019 data published by the Basel Committee Other EU EBA Call for expression of interest for new Banking Stakeholder Group Back to top
Capital Markets Prudential EU ESMA Advice to the European Commission on inducements and costs and charges disclosures under MiFID II MiFID II Review report on position limits and position management Consultation on clearing solutions for Pension Scheme Arrangements (PSAs) under EMIR Templates for quarterly non-equity systematic internaliser data Consultation on central clearing solutions for Pension Scheme Arrangements Publication of annual bond transparency calculations, systematic internalisers calculations and new bond liquidity data ESRB April 2020 ESRB risk dashboard published Int’l BIS Jurisdictions move towards full implementation of standards for financial market infrastructures (FMIs) Back to top
Investment Management Conduct EU ESMA Guidance on performance fees in UCITS and certain AIFs Other EU ESMA Technical Advice to the European Commission on weekly position reports under MiFID II Report emphasising the impact of costs on retail investor benefits Back to top Central Bank of Ireland Domestic The Central Bank of Ireland issued a statement on extension of payment breaks The Central Bank of Ireland published research on understanding SMEs in the Covid-19 pandemic Deputy Governor Sharon Donnery delivered a speech on the macroeconomic effects of Covid-19 in Ireland The Central Bank of Ireland published two research papers using real- time data on economic impact of Covid-19 Back to top
Other Cyber Int’l FSB Consultation on effective practices for cyber incident response and recovery Fintech EU EC Initial consultation on a new digital finance strategy for Europe Initial consultation on a retail payments strategy for Europe Int’l BIS Report on how FinTech can support financial inclusion CPMI paper on the payment aspects of financial inclusion in the fintech era Launch of the G20 TechSprint Initiative FSB Stage one report on enhancing cross-border payments delivered to the G20 Consultation paper on the regulatory, supervisory and oversight challenges raised by global stablecoins Sustainable Finance EU EBA Consultation on RTS for ESG related Disclosure Regulation EC Statement by the EU Technical Expert Group on Sustainable Finance: Sustainable recovery from the COVID-19 pandemic requires the right tools Consultation on the Commission's Renewed Sustainable Finance Strategy ECOFIN The European Council announced that it has adopted a unified EU classification system for Sustainable Finance (Taxonomy) ESMA No Action Letter on the new ESG disclosure requirements under the BMR and Opinion to the European Commission Int’l BIS Results of a survey the Basel Committee undertook on its members' initiatives on climate-related financial risks IMF IMF's Managing Director’s Opening Remarks at the Petersberg Climate Dialogue XI IOSCO
Statement on IOSCO efforts to address issues around sustainability and climate change Other EU ECB - SSM Letter from Andrea Enria, Chair of the Supervisory Board, to Mr Giegold, MEP, on exchange of information with anti-money laundering authorities ECB Central Bank Statement on the extension of the monetary policy strategy review until mid-2021 Announcement on Sweden joining ECB’s instant payments settlement platform Working paper on International capital flows at the security level, providing evidence from the ECB’s Asset Purchase Programme Research paper on global financial conditions and exchange rate risks Working paper on the effect of household indebtedness on the response to income and wealth shocks Update on monetary developments in the euro area in March 2020 Research paper on a framework to assess the cross-border spillover effects of macroprudential policies ESMA Report on enforcement of corporate disclosure for 2019 Int’l BIS Call for papers for joint BIS, BoE, ECB and IMF Conference on "Spillovers in a 'low-for-long' world" Back to top
Glossary AFMs = Authorised Fund Managers AI = Artificial Intelligence AIFMD = Alternative Investment Fund Managers Directive AMF = Autorité des Marchés Financiers AML = Anti-Money Laundering APA = Approved Publication Arrangement AUM = Assets under management BCBS = Basel Committee on Banking Supervision BEAR = Banking Executive Accountability Regime BIS = Bank for International Settlements BMR = Benchmarks Regulation BRRD = Bank Recovery and Resolution Directive BTS = Binding Technical Standard BoE = Bank of England CBI = Central Bank of Ireland CCP = Central Counterparty CP= Consultation Paper CTF = Counter Terrorist Financing CISO = Chief Information Security Officer CMA = Competition and Markets Authority CMU = Capital Markets Union CNMV = Comisión Nacional del Mercado de Valores CQS = Credit Quality Step CRD = Capital Requirements Directive CRR = Capital Requirements Regulation CROE = Cyber Resilience Oversight Expectations CSSF = Commission de Surveillance du Secteur Financier CTP = Consolidated Tape Provider DB = Defined Benefit DC = Defined Contribution DP = Discussion Paper DPA = Data Protection Agency DRR = Digital Regulatory Reporting EBA = European Banking Authority ECB = European Central Bank ECOFIN = Economic and Financial Affairs Council EIOPA = European Insurance & Occupational Pensions Authority EMEA = Europe, Middle East and Africa EMIR = European Market Infrastructure Regulation EONIA = Euro Over Night Index Average ESAs = European Supervisory Authorities ESG: Environmental, Social, and Governance ESMA = European Securities & Markets Authority ESRB = European Systemic Risk Board ESTER = Euro Short-Term Rate EU = European Union
Euribor = Euro Interbank Offered Rate FAMR = Financial Advice Market Review FCA = Financial Conduct Authority FinPro = Financial Protection FGCA = Financial Guidance and Claims Act 2018 FMIs = Financial Market Infrastructures FOS = Financial Ombudsman Service FPC = Financial Policy Committee FRTB = Fundamental Review of the Trading Book FS = Financial Services FSA = Financial Services Authority FSB = Financial Stability Board GBP = British pound sterling GDP = Gross Domestic Product GDPR = General Data Protection Regulation GSIBs = Global Systemically Important Banks HMT = Her Majesty’s Treasury IAIS = International Association of Insurance Supervisors IASB = International Accounting Standards Board IBOR = Interbank Offered Rate ICAAP = Internal Capital Adequacy Assessment Process ICO = Information Commissioners Office ICS = Insurance Capital Standard IDD = Insurance Distribution Directive IFRS = International Financial Reporting Standards ILAAP = Internal Liquidity Adequacy Assessment Process IM = Initial Margin IOSCO = International Organization of Securities Commissions IPU = Intermediate Parent Undertaking IRB = Internal Ratings Based ISAs = Individual Savings Accounts IT = Information Technology JST = Joint Supervisory Teams KID = Key Information Document LEI = Legal Entity Identifier LIBOR = London Interbank Offered Rate LTV = Loan to Value M&A = Mergers and Acquisitions MI = Management Information MiFID = Markets in Financial Instruments Directive MiFIR = Markets in Financial Instruments Regulation MLD = Money Laundering Directive MoU = Memorandum of Understanding MREL = Minimum requirement for own funds and eligible liabilities MTF = Multilateral Trading Facility NCA = National Competent Authority NED = Non-Executive Director NGFS = Network for Greening the Financial System
NPLs = Non-performing Loans NSFR = Net Stable Funding Ratio OCIR – Operational Continuity in Resolution ORSA = Own Risk and Solvency Assessment OTF = Organised Trading Facility OTC = Over the counter PPI = Payment Protection Insurance PRA = Prudential Regulation Authority PRIF = Prudential Regime for Investment Firms PRIIPs = Packaged Retail Investment and Insurance Products PS = Policy Statement PSD2 = Revised (second) Payment Services Directive RDR = Retail Distribution Review RFRs = Risk-Free Rates RRM = Risk Reduction Measures RTGS = Real Time Gross Settlement RTS = Regulatory Technical Standard RW = Risk Weight SA = Standardised Approach SFTR = Securities Financing Transactions Regulation SI = Systematic Internaliser SIPPs = Self Invested Personal Pensions SM&CR = Senior Managers and Certification Regime SONIA = Sterling Overnight Index Average SRB = Single Resolution Board SRF = Single Resolution Fund SREP = Supervisory Review and Evaluation Process SS = Supervisory Statement SSM = Single Supervisory Mechanism TCA = Total Capital Adequacy TCFD = Task Force on Climate-related Financial Disclosures TIBER = Threat Intelligence-based Ethical Red Teaming TLAC = Total Loss-Absorbing Capital TMTP = Transitional Measure on Technical Provisions TPP = Third-Party Providers TPR = Temporary Permissions Regime TRIM = Targeted Review of Internal Models TRR = Temporary Recognition Regime UCITS = Undertakings for Collective Investments in Transferable Securities
Contacts Sean Smith Partner, Regulatory Risk +353 (01) 417 2306 E:seansmith1@deloitte.ie John Kernan Director, Regulatory Risk +353 (01) 417 8983 E:jkernan@deloitte.ie Ray Byrne Senior Manager –Regulatory Risk T: +353 1 4173892 E:rbyrne@deloitte.ie Senan Ryan Assistant Manager -Regulatory Risk T: +353 1 417 8630 E: senryan@deloitte.ie At Deloitte, we make an impact that matters for our clients, our people, our profession, and in the wider society by delivering the solutions and insights they need to address their most complex business challenges. As the largest global professional services and consulting network, with over 312,000 professionals in more than 150 countries, we bring world-class capabilities and high-quality services to our clients. In Ireland, Deloitte has over 3,000 people providing audit, tax, consulting, and corporate finance services to public and private clients spanning multiple industries. Our people have the leadership capabilities, experience and insight to collaborate with clients so they can move forward with confidence. This publication has been written in general terms and we recommend that you obtain professional advice before acting or refraining from action on any of the contents of this publication. Deloitte Ireland LLP accepts no liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication. Deloitte Ireland LLP is a limited liability partnership registered in Northern Ireland with registered number NC1499 and its registered office at 19 Bedford Street, Belfast BT2 7EJ, Northern Ireland. Deloitte Ireland LLP is the Ireland affiliate of Deloitte NSE LLP, a member firm of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”). DTTL and each of its member firms are legally separate and independent entities. DTTL and Deloitte NSE LLP do not provide services to clients. Please see www.deloitte.com/about to learn more about our global network of member firms. © 2020 Deloitte Ireland LLP. All rights reserved.
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