Financial Services
Supervision of large, complex, international banks is undergoing a fundamental, global transformation. In the interests of safety and soundness, regulators in major markets are ramping up their engagement.
There is a consensus emerging regarding key features of supervisors' new approach. It will include a broader scope of analysis, greater engagement with management and board, and in many cases, a willingness to intervene earlier based on judgments.
The supervisors' aim is to develop a more complete picture of financial institutions and their risks. They seek to gain an "insider's insight" via a process of "triangulation," starting at the top with an improved dialogue with the board and management, then moving down to the businesses, risk management, and control functions. Supervisors will be seeking insight into strategy and competitive positioning, business models, risk appetite, and risk management and culture.
This evolving supervisory approach presents challenges. Supervisors will need enough experienced people to interact at senior levels within financial institutions on complex strategic issues. Trust must develop to allow for candid discussion and information sharing. But both supervisors and financial institutions have an interest in getting this right. As one regulator put it: "Don't [we] all have an interest in building strong global financial institutions? We need to work together." Supervisors can benefit from non-executive director counsel and support.
Regulation is forcing a change in the model of banking
At the third Bank Directors Summit in September 2011, board members representing 18 global banks were joined by three senior regulators for a discussion on the status of regulatory changes under way and the likely implications, including the unintended consequences of the current focus on systemically important financial institutions, the evolving nature of SIFI supervision, and the need to improve the manner in which banks engage policymakers on the need to balance regulatory reform and credit growth.
The changing shape of bank regulation in Europe
Bank directors met with a member of the UK’s Independent Commission on Banking (ICB), and two senior regulators from the UK Financial Services Authority, including one who served in a leadership role with the European Banking Authority, in Spring 2011, to exchange views on the ICB’s initial proposals, the changing structure and content of European and UK regulation, and the emerging nature of banking supervision.
Reinventing regulation of systemically important banks
Participants in the second Bank Directors Summit discussed global regulatory reform and what has driven its design. New laws and regulatory frameworks challenge systemically important financial institutions, and unlevel implementation may create relative advantage for certain countries and regions.