We have seen many crises in the past, but this one is in many ways unique and I cannot recall a similar set of circumstances in my 43 years in markets. Financial crises have been global before but have originated within the financial system. Natural disasters have been localised as has dislocation due to terrorism and wars. This pandemic is unique as it is the first time we have seen such dislocation in so many countries at the same time. All financial centres are going through unprecedented emergency implementation of disaster planning activation.
It is unprecedented in Financial Markets (at least in my memory!) to have so many people working from home globally. We have previously seen localised examples such as on Wall Street after the tragic event of 9/11, but nothing on this global scale. As firms dust off the business continuity plans, some are hitting problems such as systems not allowing remote trading. This requires a tweaking of rule books and system settings. For those deploying a unified, modular platform, the task is somewhat easier when suddenly so many core staff are working from home as any system changes can be made once, and once only.
Buried in the depths of the Communiqué from the G20 Finance Ministers & Central Bank Governors Meeting on the 23rd of February was a stark call to arms regarding LIBOR transition. Building on the comments from National Competent Authorities (NCA) came a clear G20 statement:
As is traditional this time of year, our good intentions of New Year resolutions fade to what we might expect to be dominant themes in 2020, and it has to be said that if certain plans are not yet well advanced you might want to get to it!
As we settled down to the first full working week of 2020, ESMA published the latest and final set of papers on the Securities Financing Transactions Regulation (SFTR) with guidelines on reporting structures. This was accompanied by the amended SFTR validation rules and a statement on Legal Entity Identifiers (LEI). The good news is that it now clarifies a number of provisions pertaining to SFTR, alongside some practical guidance.
The festive season has taken over and it is reflected in the post UK election newsfeeds for financial markets. We are moving forward into the 2020s, and people are making predictions about the new decade. But, we should not expect the exuberance, irrational or otherwise, of the Roaring Twenties a century ago!
We have moved on from the conference season which highlighted AI, Machine Learning and Algo trading as core topics de jour. Interspersed in this were concerns over information security, predictions of a greater take-up of cloud computing and regulatory attention on cybersecurity. Now we have moved well into Advent and the festive season is getting into full swing. So what has been cropping up behind the doors of the Advent calendar this year?
On 12th December the British electorate will head to the polls for the third time in four years. Each political party is asking the public to put their faith in its manifesto and to fund a splurge in public spending after years of austerity. This has sparked a broader topic of discussion in relation to (i) the extent to which the opportunity to cast our vote represents a chance to hold the conduct of our politicians to account, (ii) assess the policies of the incumbent party during the previous parliamentary period, and (iii) whether there are more efficient (and frequent) ways of making politicians accountable.
Meanwhile, today the Senior Managers Certification Regime (SMCR) comes into effect for solo-regulated firms in the financial sector.
In November last year we held a Breakfast Briefing entitled “New Horizons for Treasury Regulation”, two of the topics we covered were IBOR reforms especially from the legal aspects and the Fundamental Review of the Trading Book and predicted these would come centre stage in 2019.