Solvent exit planning webinar
In line with the PRA’s new requirements, our prudential risk experts discussed how non-systemic banks and building societies can prepare for an orderly solvent exit.
Resolvability
18 July 2024
Arguably the centrepiece of post Global Financial Crisis regulatory reforms, Recovery and Resolution Planning (RRP) aims to make it less likely that banks and investment firms will fail. When failure does occur, it seeks to minimise impacts on markets, customers, and the wider financial system.
In recent years, events like the collapse of Silicon Valley Bank and Credit Suisse have emphasised the need for greater focus on recovery and resolution planning. UK regulators have responded by publishing guidelines on wind-down planning, solvent exit planning, trading activity wind-down, and enhancing the special resolution regime. These updates highlight the importance of effective wind-down, recovery, and resolution planning.
Resolution PlanningThe 2023 bank failures involving Silicon Valley Bank (SVB) and Credit Suisse prompted regulatory investigations into lessons learned from these incidents. These failures highlighted that even banks not identified as systemically important can still be systemically significant or critical upon failure. The Bank of England summarised the lessons learned in the following 4 ways:
Recovery PlanningIn its industry feedback in May 2024; regarding the thematic review of non-systemic firms’ recovery plan, the PRA further emphasized the significance of banks and building societies’ resolvability and recovery planning. The PRA also highlighted the critical role of banks and building societies’ recovery capabilities in maintaining financial resilience during stress. Solvent ExitStarting from October 2025, non-systemic banks and building societies in the UK will be obligated to prepare for a solvent exit as part of their business-as-usual (BAU) operations, and to demonstrate their preparedness to execute a solvent exit. Encouragingly, such firms may leverage previous implementations made under their existing recovery planning regime to meet regulatory expectations. How can we help?Our subject matter experts possess a wealth of experience supporting financial institutions in wind down, recovery, and resolution planning. They come from a diverse range of backgrounds, with some having worked directly for the FCA or PRA, or within the regulatory reporting and risk management functions in other institutions. We provide bespoke wind-down, solvent exit, recovery, and resolution planning services, comprising a detailed, expert-led review on the implementation of regulatory expectations. This can provide the level of assurance that banks’ and investment firms’ management bodies can rely on. Our solutions cover the following areas:
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Case studyForvis Mazars conducted a review of the Recovery and Resolution Plans for the UK subsidiary of an international bank. We assessed both documents against the relevant regulatory expectations, with a key focus on the following:
The outcome of the project indicated that the firm should conduct a more thorough analysis of the capacity and feasibility of its recovery options, and consider its risk appetite and EWIs during the recovery planning process. Furthermore, the Firm was advised to review its stress tests to show a broader consideration of risks to its business. |
Solvent exit planning
In March, the Prudential Regulation Authority (PRA) published SS2/24 on solvent exit planning for non-systemic banks and building societies. This statement outlines the PRA’s expectations for non-systemic banks and building societies in the UK to prepare, as part of their business-as-usual (BAU) activities, for an orderly ‘solvent exit’. This requirement will come into force from 1 October 2025.
Recovery and resolution
The 2008 Global Financial Crisis revealed that major banks were in fact ‘too big to fail’. They had grown so large and complex that they needed state support given the unfathomable economic consequences of their collapse. As a result, financial regulators have introduced robust prudential measures to try to prevent such a crisis from happening again. A critical element of these post-crisis reforms...
PRA’s introduction of simplified obligations
Since 7 December 2020, firms either have been, or will be notified by their PRA supervisor that they meet the eligibility criteria for simplified obligations for recovery planning (Simplified Obligations). These obligations are set out in the updated supervisory statement SS9/17 – Recovery Planning.
Banking – Recovery and Resolution Plans
Due to the interconnected nature of financial markets, the failure of just one institution could cause instability. Banks are required to develop Recovery and Resolution Plans (RRPs) which should provide credible actions to prevent insolvency or, should it occur, minimise the negative effects of an institutions’ failure. Our team can assist you in developing an RRP which contains realistic recovery...
Key contacts
Anindya Ghosh Chowdhury Director - Risk and Regulatory Consulting - London
