Tuesday, April 21, 2009

Wake-up call for banks about cost of new liquidity regime

The New World regulatory order that is likely to be ushered in as a result of the recent financial crisis, not only means more regulation for banks, but also more cost.

Experts are already warning banks that the UK Financial Service Authority's (FSA) new requirements around strengthening liquidity standards will overload banks with reporting requirements, and as think tank JWG-IT points out, the level of reporting is on such a scale that even the regulators may not be able to understand it or use all of it. Therein lie the dangers of over-regulation.

What got us into this mess is that the regulators did not understand what they were regulating. Are they in danger of treading the same path when it comes to the new liquidity standards that will be imposed on banks and building societies as of next year?

According to JWG-IT, the FSA's survey of more than 30 firms has put the potential incremental costs of implementing the new "liquidity reporting regime" at more than £2.4 billion (JWG-IT arrived at this figure, which the FSA confirmed, based on its own analysis of the FSA survey), orders of magnitude higher than the FSA's original overall estimate of £150-£250 million.

JWG-IT says that the implementation challenges around the new liquidity standards and reporting requirements are unprecedented and that the FSA's estimates "overwhelm" the estimated costs (between £870 million and £1 billion) from one year ahead of the Markets in Financial Instruments Directive (MiFID) implementation.
It is symbolic of the afterthought regulators often pay to cost; let's implement the regulation so we are seen to be doing something and worry about the cost later. But how are firms going to fund this level of investment? And is it so onerous that banks are likely to implement piecemeal solutions or even delay liquidity risk projects further?

The comparison with MiFID is illuminating given that the cost estimates for that regulation were based on a regulatory framework that was more clearly defined. The new liquidity risk regime is less finalised than MiFID and has a much shorter implementation time frame (March 2010).

The FSA says that the more than 600 firms that will be impacted by its new liquidity reporting regime will need to devote resources to change their systems and hire more staff, which is ironic given that in the current climate banks have been shedding staff, particularly in IT departments, which will have their work cut out trying to implement the new liquidity requirements, which require "granular quantitative liquidity data" on a daily basis.

In its second consultative paper on Strengthening Liquidity Standards, the FSA estimates that the resource and staffing changes required could result in average one-off costs for UK banks of approximately £3.3 million and up to £7.4 million for "full-scope" investment firms. The UK branches of foreign banks will not escape unscathed either and could be looking at a bill of more than £500,000 each. On an ongoing basis, estimates suggest that banks will need to spend anywhere from £517,000 and £775 million, dependent on the level of "crisis reporting" required.

While the FSA's analysis of the impact the new liquidity reporting regime is likely to have on firms, "should be taken with a grain of salt" as it was prepared quickly, PJ DiGiammarino, CEO of JWG-IT, says that the cost estimates should serve as a wake-up call to banks.

He argues that global liquidity standards are needed for firms to more quickly and cost effectively implement the new regime. The Financial Stability Board, which extends the mandate of the Financial Stability Forum, is looking at the development of global standards for liquidity reporting, in addition to the reviews being undertaken by the US and the EU.


Steve Husk said...

CP 09/13 on strengthening liquidity standards has further demonstrated that the FSA is in no mood to compromise. The anticipated costs to regulated firms are continuing to rise and will clearly have an effect on overall business models. That said, the FSA clearly believes that this is a cost that the industry can and must bear. With so many changes and so many consequences still unidentifiable we may need to ask at what point the illness is better than the medicine?

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