The double thrust of the speech was to cover both the planned "twin peaks" model of UK regulation due to be phased in over the next year or so, as well as implementation of Solvency II. There is a genuinely aggressive tone in the wording, which betrays a certain impatience with what the guys at Canary Wharf have seen to date in Self Assessment Templates and pre-application activity. I extracted the following from it;
- Highlighting that prudential and conduct issues will be dealt with by separate peaks, allowing a more focused approach.
- A PRA agenda which seems to tread on old ground (assessing the vulnerability of business models, and whether they have a run-off plan in place). The main shift is perhaps a heavier focus on that plan's viability during a crisis, learning one hopes from the real-time experiences of the last 5 years.
- A complimentary, but very unsubtle onus on the subject of reverse stress testing, or "what would break the company" which, bearing in mind the relatively light materials available on the topic from the FSA (a few pointers in here being the most recent release on p2), would suggest firms may need to look elsewhere to bolster their RST approach (TW for example have a decent piece here).
- A very surprising revelation that the 'appropriateness' of the Standard Formula to firms who have elected against internal modelling is essentially a 2013 piece of work - what does that mean for anyone who is found to be using it 'inappropriately', bearing in mind the proximity of implementation (are we to understand that this is a lesser crime than having a stab at modelling and coming up short on the documentation front)?
- "Competence and quality" of senior management will be scrutinised from a system of governance perspective - I like this, on the premise that it would be relatively easy to build a technically compliant structure and populate it with unsufficiently trained/briefed staff. Their bullet point list of what they will be asking around (focused on quality of MI provided, understanding of reverse stresses, quantification of risks in risk appetite frameworks, and availability of management actions, modelled and non-modelled, under duress) should be put in front of your nearest directors tomorrow!
- A definition (of sorts) of proportionality as "the amount of work we expect firms to do to demonstrate a requirement has been met", though adding a vice versa to cover how much time they will devote to assessing it.
- No in-depth reviews of SATs scheduled, nor do they expect a piece of evidence for each one of the 300 model approval requirements (god forbid this turns a bit tick-boxy for the sake of administrative convenience!)
- Making "no apologies" for disagreeing with applicants' own assessments of the quality of their submission paperwork, while suggesting there is a grading criteria already in place (adequate|comprehensive|complete) - not publishing the more critical end of that spectrum it would appear!
- Note that the interaction of component parts of models, as well as correlation/diversification and extreme events in the tail, will receive more attention.
- "Much higher degree of feedback than has been the case to date" should be expected by the IMAP firms in near future, with the FSA being "much clearer on [their] view of progress", and potentially "ceasing to work with you and exiting you from the process" - this is seemingly driven off the back of the pre-application work to date and some peer group review work leaving them in a spot where they can separate the wheat from the chaff.
- Note that the transition between pre-application to submission is where they will make a "substantive decision as to a firm's progress" - explains the Lloyd's position I guess, though I'm not certain a less substantial body may have been reprieved judging by the tone of this speech.
- A final flourish around what has been witnessed to date, where they have specifically singled out the following areas of tardiness as signs of a ropey application: falling behind one's own implementation plans; validation workstreams being "significantly behind" and with narrow scopes; expert judgements not being properly documented or challenged; supporting documentation generally weak, and model change policies which have yet to conquer the challenge of "major/minor" definitions, let alone what a "qualitative major change" may consist of. I would add that these themes were covered at the industry briefing at the end of February (from p9), just not as definitively.
Well don't just stand there, get cracking!