Small Domestic Deposit Takers (SDDT) Regime

The PRA is introducing a more proportionate prudential regime for less systemically important banks and building societies. This will be known as the ‘Small Domestic Deposit Takers’ regime.

Previously known by the name ‘Strong and Simple’, the Small Domestic Deposit Takers (SDDT) regime will be a simplified prudential framework which will apply to banks and building societies that are neither systemically important nor internationally active. The SDDT regime seeks to address concerns that the regulatory framework for smaller banks and building societies has become too complex and disproportionate as a result of post-financial crisis reform measures.

The intention is that this will increase competition and innovation in the UK banking sector. The regime is intended to be flexible enough to cater for a range of business models and will continue to meet the PRA’s primary objective of ensuring that regulated firms operate in a safe and sound of manner.

In December 2023 the PRA published a policy paper on the scope of the SDDT regime. It also outlined the regime's liquidity and disclosure requirements. These came into force on 1 July 2024. Further detail has been promised on the capital framework in Q3 2024.

How can we support you?

We can support you and your firm with the following:

Training to ensure firms are up to date with the new regime.
Advising on implementation, including timelines.
Supporting the update of internal procedures and processes.
Providing review and gap analysis against the new regulatory expectations.
Regulatory Reporting support.
Capital and Liquidity analysis and support.

We have created some useful resources to support your firm's implementation of the SDDT regime.

If you would like to find out more, please get in touch with our team.

Get in touch

Small Domestic Deposit Takers (SDDT) Regime timeline

Small Domestic Deposit Takers (SDDT) implementation timeline - graph

SDDT Regime FAQs

What factors should a bank or building society consider when deciding whether to adopt the Small Domestic Deposit Takers Regime?

Senior management should focus on 3 areas when considering if the SDDT Regime makes sense for their institution:

Quantify the impact of the SDDT Regime on their capital and liquidity requirements. While the liquidity guidance has already been published firms should wait until capital guidance (expected Q3 2024) is out before making a final decision on whether to enter the SDDT Regime.
Firms should review how SDDT will impact key prudential documentation regulatory returns. Firms should prioritise understanding the benefit of simplification to the NSFR and ALMM returns, Pillar 3 disclosures, ILAAP and potentially ICAAP.
Firms will also need to assess the impact of the reforms on Strategy, Policies and Procedures. For example, if your firm is considering applying for IRB models permissions, which are not allowed under the SDDT Regime, it may make sense to not apply for SDDT, despite being eligible.

What are the benefits of the Small Domestic Deposit Takers Regime?

The SDDT Regime can be an attractive alternative to small eligible banks as it offers the following benefits:

Increased competitiveness: From a liquidity perspective, the SDDT Regime introduces the Retail Deposit Ratio (RDR) which aligns better with the funding composition of smaller banks. In practice, this allows retail-focus deposit takers to maintain lower liquidity holdings compared to the traditional Liquidity Coverage Ratio (LCR), thereby enhancing their competitive hedge.
Reduced regulatory burden: Eligible institutions face less complex reporting and disclosure requirements (e.g. four subsections of the ALMM returns have been eliminated) making it easier for banks and building societies to meet their obligations.
Cost savings: By reducing administrative overhead and compliance costs, firms can allocate resources more efficiently by focusing on developing area of the business such as innovation.

Who is eligible for the Small Domestic Deposit Takers Regime?

Eligible firms for this regime will generally be expected to meet the following criteria, though the PRA may exercise flexibility based on specific circumstances*.

Size: Total assets on average over the past three years of no more than £20 billion.
Domestic activity: The share of credit exposures located in the UK is at least 75% at all times and at least 85% on average over the past three years.
Limited trading activity:
Trading book business was equal to or less than both £44 million and 5% of total assets in recent months.
Overall net foreign exchange position was equal to or less than 2% of own funds in recent months
No positions in commodities or commodity derivatives.
No Internal Ratings Based (IRB) approach.
Does not provide clearing, transaction settlement, custody or correspondent banking services to other banks and building societies unless they are members of the firm’s immediate group.
Does not operate a payment system.
Does not have a non-UK parent.

*Firms can apply for a waiver/modification application form to bypass certain scope criteria. More details can be found on the BoE website.

Operational opportunities and challenges

With the introduction of the Strong & Simple (S&S) regime, UK banks will be predominantly categorised as under either the S&S regime or the Capital Requirement Regulation (CRR). For firms considering whether to apply to the S&S regime a thorough evaluation of the respective regulatory implications of either approach is required.

Key observations on PRA’s policy statement

The Policy Statement (PS 15/23) is the long-awaited, finalised version of the criteria for entry, disclosure and liquidity requirements for the Strong and Simple regime. We have outlined the key points from this policy statement for firms.

Capital insights from international regimes

This article provides insight into how the future of the UK capital framework may look based on comparisons with international peers.

Pillar 3 Remuneration Disclosures (CP14/23 review)

Bank of England issued a new consultation paper (CP14/23) that proposes changes to ensure that Pillar 3 remuneration disclosure requirements are more proportional for smaller firms within the Financial Services industry. This will mean smaller banks will report a reduced number of remuneration disclosures. The article will primarily discuss the impact on firms that meet the Strong and Simple criteria...

Application to third-country firms

Strong and Simple seeks to simplify the prudential framework for non-systemic domestic banks and building societies. The framework is geared towards UK-headquartered firms, but the PRA acknowledges that some third-country firms may benefit. This article outlines how the PRA proposes to work with third-country firms to integrate them into the simpler regime.

Strong and Simple – Does this apply to your firm?

The Strong and Simple regime could present potential advantages to firms, including cost reductions and increased competitiveness due to more proportionate regulatory requirements. This article aims to provide a clear understanding of which firms could be eligible for the new regime following PRA consultation (as of Q2 2023).

Prudential regime banks building societies UK

There is currently a proportionality problem for small firms as they, just like larger ones, incur significant costs for understanding, interpreting and operationalising prudential requirements.

Banking - Q4 2022

There were several regulatory developments in Q4 2022, including the launch of the consultation paper on Basel 3.1. This was followed by the publication of the 2023 priorities letter from the PRA in January 2023. In this update, we have discussed the key regulatory developments from Q4 2022, and also discussed the PRA priorities letter from Q1 2023.

PRA’s strong and simple regime

For many years, the PRA has been applying a proportional approach to both regulating and supervising smaller banks, but there is a marked difference as supervision has been more pronounced.