What all banks and financial institutions dread in the ‘always on’ world of digital is the dreaded “we’re sorry, we’re having problems right now” being displayed to all customers. It is something the regulators are concerned about too.
Following regulatory forbearance due to Covid and the resultant extensions to the implementation dates, it is time to review arrangements to comply with UMR. The number of in-scope entities will drastically increase as we near the Phase 5 & 6 dates. Entities will be subject to the rules from 1st September 2021 if the aggregate month-end average notional amount is above EUR 50 billion and from the 1st September 2022 if above EUR 8 billion. This will bring into scope over a thousand firms and result in a requirement to re-paper clients accordingly. These amounts equally apply to the UK as the recent consultation by the PRA & FCA outline some proposed changes but do not convert the pre-Brexit notional amounts to GBP.
In our whitepaper, What to look for when selecting a treasury management system, we included a section on digital currencies. The whitepaper referenced our blog from just over a year ago (An unanswered question from Davos) that posited the question of when we would activate our Crypto/Digital/CBDC functionality in our treasury, sales and trading systems. At that time, we had undoubtedly seen a series of decisive moves on CBDC’s and stable coins. A year on, we see strong institutional uptake for cryptocurrencies from asset and wealth managers and an emerging interest from corporates. These are the customers of banks, and so it is likely that the coming weeks will feature news of banks looking to offer trading and post-trade capabilities for this emerging asset class.
Markets appear, according to commentators, to be pricing in a last-minute deal between the European Union and the United Kingdom. This would certainly fit various other scenarios we have seen with last-minute eleventh-hour deals involving the EU.
Following on from the MAR report in my last blog comes one on a consultation from ESMA concerning the Organised Trading Facility (OTF) Regime. The accompanying paper provides an overview of the functioning of the OTF regime. It discusses the definition of OTF’s, the use of discretion in the execution of orders and the practice concerning the use of matched principal trading.
As we approach Halloween market abuse has come back to haunt the FX market. Our Advent Blog last year covered the ESMA Consultation Paper on the provisions of the Market Abuse Regulation (MAR) and highlighted the fact that spot FX is not covered by MAR.
For some time in the UK the regulators and authorities have tried to introduce true competition to the traditional banks. Much debate has occurred as to the rights and wrongs of allowing a new grouping of Challengers, Neos and FinTech enter the banking market with a lighter regulatory touch to the incumbents.
Given the longstanding focus on the familiar, well-used trading benchmarks and indices currently in use but due to be retired or changed, it’s quite normal to feel that you don't know your SARON from your €STR!
I have been catching up on some light reading in the glorious English sunshine. One report in particular caught my eye; the Bank for International Settlements (BIS) Committee on Payments and Market Infrastructures released a paper in July
The regulation for Uncleared Margin Rules (UMR) was set in motion at the 2009 G20 meeting following the global financial crisis.
A triumvirate of the Working Group on Risk-Free Reference Rates (RFRWG), the FCA and the Bank of England published joint statements in March and April (see my previous blog LIBOR Wars) reiterating that firms must move away from referencing LIBOR and reduce the stock of legacy LIBOR contracts.
The effect of the pandemic has been a mixed bag for many involved in our markets. The increase in volatility has seen a boost to trading activities and RegTech has been busy innovating to help overcome the compliance issues of remote working. With banks splitting personnel between the office, disaster recovery sites and working from home, issues have arisen that will spur technological development and system renewals.