Financial Services Regulatory Update – October 2021 Round Up

Banking Package 2021

On 27 October 2021, the European Commission (the “Commission”) adopted its review of EU banking rules (the “Banking Package”) here. The proposals set out in the Banking Package are intended to finalise implementation of the Basel III Framework here, assist the financing of the European economy in the context of the post-COVID-19 crisis recovery and contribute to a “green transition”.

The Banking Package consists of:

• a legislative proposal to amend the Capital Requirements Directive (“CRD”) (here);
• a legislative proposal to amend the Capital Requirements Regulation (“CRR”) (here); and
• a separate legislative proposal to amend the Capital Requirements Regulation in the area of resolution (here).

The Banking Package focuses on three key areas: Basel III reforms, sustainability and enhanced supervision.

The next step is for the European Parliament and the Member States in the Council to discuss the final legislative texts on the basis of the Banking Package (timing is uncertain but these discussions may take up to 2 years). The Commission has stated it proposes to give banks and supervisors time to properly implement the reform in their processes, systems and practices and will start applying the new rules from 1 January 2025.

CBI “Dear CEO” Letter

On 3 November 2021, the CBI issued a letter to the Chairs and CEOs of regulated firms (here) identifying five areas of focus for its supervisory expectations relating to sustainability:

• governance,
• risk management,
• scenario analysis,
• strategy and business model risk, and
• disclosures.

The CBI also issued pledge (here) on climate change action, highlighting the pivotal role of the financial system in the transition to a carbon neutral future and setting the treatment of climate change as a strategic priority. As a member of the Network for Greening the Financial System (“NGFS”), the CBI also noted the need for international cooperation and endorsed the NGFS ‘Glasgow Declaration’.

The CBI also announced the establishment of a Climate Risk and Sustainable Finance Forum (the Climate Forum) for stakeholders to share knowledge and understanding of the implications of climate change for the Irish financial system. The CBI confirms that details of its first meeting, expected in the coming months, are expected shortly.

ECB “Dear CEO” Letter

On 18 October 2021, the ECB issued a letter to significant institutions confirming that the ECB will conduct climate-related stress tests in 2022 (here).

The key points of the ECB’s letter were as follows:

• the ECB considers the stress test to be a learning exercise for banks and supervisors;
• no direct capital impact via the Pillar 2 guidance is envisaged (although the ECB notes a possible indirect impact, via the institutions’ supervisory assessment (“SREP”) scores); and
• the stress test will consist of 3 modules ((i) a questionnaire assessing how banks are building their climate stress test capabilities as a risk management tool, (ii) a peer benchmark analysis and (iii) a bottom-up stress test addressing physical and transitional risks, ie, effects of extreme weather events, increase in carbon emission prices etc.)

The methodology for the climate risk stress test is set out here.

The ECB confirms that this stress test will be carried out in tandem with other measures such as a thematic review of banks’ climate-related and environmental risk management practices.

CBI speech – (SEAR – IAF - Enforcement)

On 13 October 2021, Derville Rowland, Director General of Financial Conduct at the CBI, delivered a speech on the “Central Bank’s evolution of enforcement" (here).

Ms Rowland discussed the CBI’s approach to developing its enforcement strategy in the context of:

• the impending Individual Accountability Framework;
• ensuring the targeted deployment of its enforcement powers with transparent outcomes; and
• further developing its framework of credible deterrence.

Ms Rowland noted that the CBI expected more cases to be determined by way of inquiry and while robust enforcement action will continue to underpin the CBI’s powers, the CBI would rather firms focus on preventing, identifying, and acting upon misconduct in the first instance, than face punishment down the line.

Resolution - MREL

The CBI has published a second edition of its Approach to Resolution For Banks and Investment Firms (here) to reflect changes introduced following amendments to legislation, including the Single Resolution Mechanism Regulation and Bank Recovery and Resolution Directive. The Approach to Resolution document is intended to provide an overview of the resolution framework, outline the CBI's general perspectives on resolution planning and illustrate how the CBI would exercise its resolution and liquidation powers in a failure event.

The CBI has also published its approach to minimum requirements for own funds and eligible liabilities (“MREL”) (here). This document provides an overview of the purpose of MREL and related matters in the resolution framework and outlines the CBI’s powers and discretions with regards to MREL and related matters.

The statutory transition period for MREL and subordination expires on 1 January 2024, there is a binding intermediate target to be met by 1 January 2022 and an informative intermediate target to be met by 1 January 2023.

Industry Funding

The CBI has issued its publication “Funding Strategy and Guide to the 2021 Industry Funding Regulations” (here).

The CBI confirms this publication is intended to provide a guide to the Industry Funding Regulations for 2021 which have been set to recover industry’s share of 2020 financial regulation costs. The CBI states there are 3 principal aims in its funding strategy:

• to increase proportion of costs chargeable to industry and reduce reliance on taxpayer;
• predictable, transparent and proportionate pricing; and
• to reduce complexity.

Central Register of Beneficial Ownership of Trusts

The date for trustees of relevant trusts to register details of the beneficial ownership of their trust on the Central Register of Beneficial Ownership of Trusts (“CRBOT”) was 23 October 2021 for trusts that were created on or before 23 April 2021 (here). Trusts created after this date have six months from the date of creation to submit information to CRBOT. Revenue have set up a CRBOT portal accessible via the CRBOT area of www.revenue.ie.

See our briefing with further detail (here).

Resolution – BRRD technical standards

On 4 October 2021, Commission Implementing Regulation (EU) 2021/1751 of 1 October 2021 was published in the Official Journal. The Implementing Regulation lays down implementing technical standards for the application of the Bank Recovery and Resolution Directive with regard to uniform formats and templates for notifications of determination of the impracticability of including contractual recognition of write down and conversion powers (here).

Non-compliance with minimum reserve requirements

On 15 October 2021, ECB Regulation (EU) 2021/1814 of 7 October 2021 amending Regulation (EC) No 2157/1999 on the powers of the ECB to impose sanctions  and ECB Decision (EU) 2021/1815 of 7 October 2021 on the methodology applied for the calculation of sanctions for non-compliance with the requirement to hold minimum reserves and related minimum reserve requirements were published in the Official Journal (here and here).

The Regulation and related Decision outline the methods to be applied by the ECB to calculate sanctions in cases of non-compliance with minimum reserve requirements. The Regulation and Decision shall enter into force on 3 November 2021.

(For information, the introduction of the above Decision has led to the withdrawal of a historic ECB notice on the imposition of sanctions for breaches of the obligation to hold minimum reserves (here)).

LIBOR transition

On 22 October 2021, Commission Implementing Regulation (EU) 2021/1848 on the designation of a replacement for the benchmark Euro overnight index average (here) was published in the Official Journal. The Implementing Regulation provides that in-scope references to EONIA should be replaced by the euro short-term rate (€STR) and a specified fixed spread adjustment.

On 22 October 2021, Commission Implementing Regulation (EU) on the designation of statutory replacement for certain settings of CHF LIBOR (here) was published in the Official Journal. The Regulation provides that in-scope references to CHF LIBOR should be replaced with designated replacement rates (SARON Compound Rate plus the relevant adjustment spread) from 1 January 2022.

Credit Unions

On 20 October 2021, the Credit Union (Amendment) Bill was laid before the Oireachtas (here). This Bill proposes to amend certain provisions of the Credit Union Act 1997 to:

• provide for the amendment of the objects of credit unions to include the provision to its members of additional financial services as are for their mutual benefit;
• provide for the establishment of a Credit Union Policy Committee; and
• provide for miscellaneous matters relating to credit unions.

Passporting notifications under CRD

On 20 October 2021, the Commission adopted a Delegated Regulation in respect of amendments to regulatory technical standards (“RTS”) on passporting notifications under the CRD IV (here). The Delegated Regulation will amend Commission Delegated Regulation (EU) 1151/2014 which contains RTS on the information to be notified when exercising the right of establishment and the freedom to provide services under CRD IV.

In particular, the Delegated Regulation shall require credit institutions to:

• indicate the intended start date of each passported activity;
• provide information on assumptions that underpin financial plans; and
• provide a statement indicating the measures undertaken to ensure that the credit institution no longer holds deposits or repayable funds from the public through the branch.

RTS for assessing compliance with IRB approach

On 20 October 2021, the Commission adopted a Delegated Regulation (here) containing RTS on the methodology competent authorities should use for assessing compliance of credit institutions and investment firms with the requirement to use the internal ratings based approach (the “IRB Approach”) under the Capital Requirements Regulation.

The Delegated Regulation sets out standards for competent authorities for the assessment of an institution’s compliance with IRB requirements when:

• an institution initially applies to use the IRB Approach,
• applies to use the IRB approach for certain types of exposures in accordance with the sequential implementation plan,
• applies for implementation of material changes to the IRB approach; and
• applies to return to the use of less sophisticated approaches.

Market risk

On 22 October 2021, the EBA published its final draft RTS (here) on gross jump-to-default (“JTD”) amounts. JTD amounts are a component in the calculation of own funds requirements for market risk.  The draft RTS set out how gross JTD amounts are to be determined for the purpose of calculating institutions’ exposures in the trading book under the alternative standardised approach for market risk in scope of the Default Risk Charge (“DRC”). The DRC is a capital requirement intended to capitalise default risks in the trading book.

The final draft RTS will now be considered by the Commission.

Benchmarking

On 5 October 2021, the Commission published two Implementing Regulations which relate to the submission by institutions of the results of their calculations of own funds requirements based on internal approaches:

• Commission Implementing Regulation amending Implementing Regulation (EU) 2016/2070 as regards benchmark portfolios, reporting templates and reporting instructions to be applied in the Union for the reporting referred to in Article 78(2) of CRD IV (here); and
• Commission Implementing Regulation amending Implementing Regulation (EU) 2016/2070 laying down implementing technical standards for templates, definitions and IT-solutions to be used by institutions when reporting to the EBA and to competent authorities in accordance with Article 78(2) of CRD IV (here).

Third country equivalence

On 4 October 2021, Commission Implementing Decision (EU) 2021/1753 of 1 October 2021 on the equivalence of the supervisory and regulatory requirements of certain third countries and territories for the purposes of the treatment of exposures in accordance with Regulation (EU) No 575/2013 of the European Parliament and of the Council was published in the Official Journal (here).

The annexes of the Commission Implementing Decision set out the third countries and territories which shall be considered as applying supervisory and regulatory arrangements equivalent to those applied in the Union for credit institutions, investment firms and exchanges.

Corrigendum to Regulation (EU) 2019/876 null and void

On 27 October 2021, the Official Journal of the European Union published a notice (here) that  Corrigendum to Regulation (EU) 2019/876 of the European Parliament and of the Council of 20 May 2019 amending the Capital Requirements Regulation as regards the leverage ratio, the net stable funding ratio, requirements for own funds and eligible liabilities, counterparty credit risk, market risk, exposures to central counterparties, exposures to collective investment undertakings, large exposures, reporting and disclosure requirements, and Regulation (EU) No 648/2012 should be considered null and void.

Insurance (Miscellaneous Provisions) Bill

On 20 October 2021, the Department of Finance published the General Scheme of the Insurance (Miscellaneous Provisions) Bill (the “General Scheme”) (here). The General Scheme proposes that the CBI provide a report to the Minister for Finance (within an 18-month timeframe of adoption of the legislation) on:

• any steps it takes to address the practice of price walking;
• the CBI’s views in relation to oversight of pricing practices; and
• the CBI’s views on whether further legislation or regulatory action is required.

The General Scheme also proposes amendments to the Central Bank (National Claims Information Database) Act 2018, the Consumer Insurance Contracts Act 2019 and the European Union (Insurance and Reinsurance) Regulations 2015.

The next step is for the Minister of State with responsibility for Financial Services, Credit Unions and Insurance to write to the Chair of the Committee on Finance, Public Expenditure and Reform and the Taoiseach regarding pre-legislative scrutiny. The Department of Finance confirms that officials will engage with the Office of the Parliamentary Counsel to the Government to begin drafting the legislation on the basis of the General Scheme.

It should be noted that the CBI’s consultation on the matter of differential pricing (including price walking) closed on 22 October 2021, therefore we can expect that the CBI will continue its progress on these matters in parallel to the legislative development of the General Scheme.

CBI Regulatory Firms FAQ Update

The CBI updated its Regulatory Firms FAQ in respect of making distributions and payments of variable remuneration by (re)insurance firms in light of the COVID-19 pandemic (here).

The CBI outlines that it continues to expect all (re)insurance firms and their Boards to exercise prudence in respect of dividend distributions, share buy-backs or other similar transactions, and variable remuneration, and to carefully assess the impact of such proposed distributions on the financial resilience of the firm and in particular, its solvency and liquidity positions on a forward looking basis. The CBI will keep this position under review and may update it further at a later date.

Solvency II – revision of euro amounts in line with inflation

Notice regarding the adaptation in line with inflation of the amounts laid down in the Directive 2009/138/EC of the European Parliament and of the Council on the taking-up and pursuit of the business of Insurance and Reinsurance (Solvency II) here.

On 19 October 2021, the Commission issued a notice that euro € amounts specified in Directive 2009/138/EC (the “Solvency II Directive”) will be revised (pursuant to article 300 which requires amount specified in euro to be revised every five years).

Member States are required to implement the provisions of this notice by 19 October 2022.

CBI – implementation notice of competent authority discretions

The CBI has published a notice ‘Implementation of Competent Authority Discretions in the European Union (Investment Firms) Regulations 2021 and Regulation (EU) No 2019/2033’ (here) setting out its requirements and guidance in relation to the implementation of certain competent authority discretions arising under the Investment Firms regulatory framework (i.e., the Investment Firms Regulation, the Investment Firms Directive and related statutory instruments). These discretions relate to the application of CRR/CRDIV to certain firms, capital and liquidity, remuneration and supervision.

The CBI states that in exercising its discretions it will be guided by the following general principles:

• To adopt a prudent approach;
• To choose the more risk sensitive option, where one is identified; and
• To be consistent and transparent in the intended approach, and the reasoning behind it.

Money Market Funds

The CBI issued an updated guidance ‘Reporting requirements for Fund Management Companies of Irish Authorised Money Market Investment Funds’ in October (here). The purpose of this guidance is to provide information and direction on the completion of money market fund reporting by Fund Managers.

RTS – Disclosure of investment policy

On 19 October 2021, the EBA published its final report on draft regulatory standards in respect of disclosure of investment policy by investment firms under Article 52 of Regulation (EU) 2019/2033 on the prudential requirements of investment firms (here).

The RTS are intended to specify templates for investment policy disclosure of investment firms pursuant to Article 52 of the Investment Firms Regulation. Firms are required to disclose the following information:

• proportion of voting rights attached to shares held;
• voting behaviour;
• use of proxy advisor firms; and
• voting guidelines.

Annex I of the RTS contains templates and tables and Annex II of the RTS sets out detailed instructions. The RTS will now need to be reviewed by the Commission.

MiFID ancillary test

On 20 October 2021, the Delegated Regulation supplementing MiFID II by specifying the criteria for establishing when an activity is to be considered to be ancillary to the main business at group level was published in the Official Journal (here). The Delegated Regulation will come into force on 9th November 2021.

The Delegated Regulation includes the introduction of the ‘De-Minimis Threshold Test’ and the amendment of existing ancillary tests - changing the thresholds for the ‘Trading Test’ and the ‘Capital Employed Test’.

Investment recommendations on social media

On 28 October 2021, the European Securities and Markets Authority ("ESMA") issued a public statement on investment recommendations made on social media (here), clarifying what investment recommendations are, how to post them on social media platforms and what consequences may flow from breaches of the EU Market Abuse Regulation (namely, fines and referral to public prosecutors).

SFDR Disclosures

On 22 October 2021, the ESAs published a joint final report (here) containing RTS relating to the content and presentation of sustainability disclosures under Articles 8(4), 9(6) and 11(5) of the Sustainable Finance Disclosure Regulation ("SFDR").

Articles 8(4), 9(6) and 11(5) of SFDR were inserted in the SFDR through Article 25 of the Taxonomy Regulation. Following this amendment, the ESAs were mandated to develop RTS on taxonomy-related product disclosures. The draft RTS include provisions relating to the content and presentation of product disclosures and contain templates for pre-contractual and periodic product disclosures.

The ESAs’ final report proposes to consolidate the taxonomy-related SFDR disclosures and other SFDR disclosures. In this respect, the ESAs note the Commission’s intention to adopt all the SFDR RTS in one delegated act (a ‘single rulebook’) with an application date of 1 July 2022.

AIFMD Q&A

On 29 October 2021, the CBI issued the 43rd edition of the AIFMD Q&A, updating Q&A ID 1139 (here), which adds aircraft to the list of permissible non-financial asset classes a Depositary of Assets other than Financial Instruments may safe-keep.

UCITS Q&A

On 29 October 2021, the CBI issued the 35th edition of the UCITS Q&A, which includes a new Q&A, ID 1104 (here). The new Q&A sets out the CBI’s expectations in relation to the filing of Key Investor Information Documents (“KIIDs”) for UCITS which are implementing the ESMA’s Performance Fee Guidelines with effect from 31 December 2021.

CBI Notice of Intention – ESMA marketing guidelines

On 1 October 2021, the CBI issued a notice of intention in relation to the application of the ESMA Guidelines on marketing communications under the Regulation on cross-border distribution of funds (here). The ESMA Guidelines will apply from 2 February 2022. The CBI states it will in due course consult on the incorporation of a requirement in the Central Bank UCITS Regulations and AIF Rulebook that all UCITS management companies, AIFMs, EuVECA managers and EuSEF managers shall adhere to the ESMA Guidelines.

Consequential updates were made to the AIFMD and UCITS Q&A which we covered in our Financial Services Regulatory Update – September Round-Up (here).

PRIIPs – call for evidence

On 21 October 2021, the ESAs opened a call for evidence from stakeholders regarding a review of the Packaged Retail and Insurance-based Investment Products Regulation (the “PRIIPs Regulation”) (here).

The ESAs’ call for evidence relates to:

• the practical application of the key information document (“KID”) such as its use by financial advisors or the use of digital media;
• the scope of the PRIIPs Regulation; and
• the degree of complexity and readability of the KID.

The call for evidence is open until 16 December 2021.

PRIIPs – KID – Extension of timeline

On 7 October 2021, the Economic and Monetary Affairs Committee of the European Parliament issued a draft report proposing that the transitional arrangements contained within the proposed regulation amending Regulation (EU) No 1286/2014 as regards the extension of the transitional arrangement for management companies, investment companies and persons advising on, or selling, units of undertakings for collective investment in transferable securities (UCITS) and non-UCITS be extended from 30 June 2022 to 31 December 2022 (here).

The proposed extension would require fund managers to produce the PRIIP KID from 1 January 2023, instead of 1 July 2022, as originally proposed by the Commission.

Transposition of amendments to STS securitisation framework

On 18 October 2021, The European Union (General Framework for Securitisation and Specific Framework for Simple, Transparent and Standardised (“STS”) Securitisation) (Amendment) Regulations (S.I. No 561 of 2021) were adopted (here).

The purpose of these Regulations is to make amendments to an existing statutory instrument - The European Union (General Framework for Securitisation and Specific Framework for Simple, Transparent and Standardised Securitisation) Regulations 2018.

The amendments are intended to give effect to Regulation (EU) 2021/557 of the European Parliament and of the Council of 31 March 2021 amending Regulation (EU) 2017/2402 laying down a general framework for securitisation and creating a specific framework for STS securitisation to help the recovery from the COVID-19 crisis.

The objective of Regulation (EU) 2021/557 is to extend the STS securitisation framework to synthetic securitisation and to remove regulatory obstacles to securitisation of non-performing exposures to further increase lending capacities without lowering the prudential standards for bank lending to help the recovery from the COVID-19 crisis.

STS notifications

On 7 October 2021, ESMA published its final report on the content and format of STS notifications for on-balance sheet synthetic securitisations (here).

The final report includes draft regulatory technical standards on the information required to be disclosed in STS notifications and draft implementing technical standards establishing STS notification templates.

ESMA notes that the feedback it received was limited, so the final report largely reflects the original proposals in the consultation. The draft RTS have been submitted to the Commission for endorsement.

FATF virtual asset/virtual asset provider guidance

On 28 October 2021, the Financial Action Task Force (“FATF”) published the updated version of its guidance (here) on the risk-based approach to virtual assets (“VAs”) (also known as cryptoassets) and virtual asset service providers (“VASPs”), explaining how its anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) standards apply to VAs and VASPs.

Selected Consultations, Discussion Papers, Speeches and Reports Published

AFME - Position paper on limitations to Capital Buffer usage during the Covid-19 pandemic (here)

AFME - Anti-Money Laundering Transaction Monitoring in the Markets Sector (here)

AFME - Position on non-SDR Priorities for the CSDR Review (here)

BCBS, IOSCO and CPMI - joint consultative report on a review of margining practices (here)

BIS - A taxonomy of sustainable finance taxonomies (here)

BIS - Policy proposals to enhance money market fund resilience: Final report (here)

BPFI - Banks to play role in carbon neutral future (here)

CPMI and IOSCO - Consultative report - Application of the Principles for Financial Market Infrastructures to stablecoin arrangements (here)

CPMI - Call for ideas on solutions to expand PvP settlement (here)

EBA – Opinion on the treatment of client funds under deposit guarantee schemes (here)

EBA - Consultation paper on Draft Regulatory Technical Standards amending the Commission Delegated Regulation (EU) 2018/389 supplementing Directive (EU) 2015/2366 of the European Parliament and of the Council with regard to regulatory technical standards for strong customer authentication and common and secure open standards of communication (here). The consultation closes on 25 November 2021.

EBA - The EBA Methodological Guide - Indicators for Risk Assessment and Resolution & Detailed Risk Analysis Tools - October 2021 (here)

EBA – Repeal of Guidelines on the security of internet payments under the former Payments Services Directive (PSD1) (here)

EBA - 2022 Work Programme (here)

EBA – Benchmark rate transition risks analysis of the EU/EEA banking sector’s exposures linked to benchmark rates and transition risks relating to interbank offered rates (here)

ECB - Frank Elderson, Member of the Executive Board of the ECB and Vice-Chair of the Supervisory Board of the ECB ‘The role of supervisors and central banks in the climate crisis’ (here)

ECB - Isabel Schnabel, Member of the Executive Board of the ECB ‘Lessons from an unusual crisis’ (here)

ECB - Edouard Fernandez-Bollo, Member of the Supervisory Board of the ECB ECB Banking Supervision's post-pandemic priorities - the way forward (here)

ECB - Fabio Panetta, Member of the Executive Board of the ECB ‘Stay safe at the intersection: the confluence of big techs and global stablecoins’ (here)

ECB - Frank Elderson, Member of the Executive Board of the ECB and Vice-Chair of the Supervisory Board of the ECB ‘Overcoming the tragedy of the horizon: requiring banks to translate 2050 targets into milestones’ (here)

ECBC - European Covered Bond Fact Book 2021 (here)

ESMA – Call for evidence on the European Commission mandate on certain aspects relating to retail investor protection (here). Comments are to be submitted by 2 January 2022.

ESRB – Working Paper Series - ‘Do liquidity limits amplify money market fund redemptions during the COVID crisis?’ (here)

European Commission – 2022 Work Programme (here)

European Commission – Call for Advice on securitisation framework (here)

European Parliament - Preventing money laundering in the banking sector - reinforcing the supervisory and regulatory framework (here)

FATF - Digital Transformation of AML/CFT for Operational Agencies: Detection of Suspicious Activities and Analysis of Financial Intelligence (here)

FSB - Regulation, Supervision and Oversight of “Global Stablecoin” Arrangements: Progress Report on the implementation of the FSB High-Level Recommendations (here)

IMF Global Financial Stability Report - COVID-19, Crypto, and Climate: Navigating Challenging Transitions (here)

IOSCO – Principles on outsourcing Final Report (here)

ISDA - OTC Derivatives Compliance Calendar 2021 (here)

ISDA - implementation of new standard definitional booklet for interest rate derivatives (here) and (here)

OECD -  ESG Investing and Climate Transition - Market Practices, Issues and Policy Considerations (here)

OECD - Financial markets and climate transition: Opportunities, challenges and policy implications (here)

SRB - Operational Guidance for Banks on Separability for transfer tools (here)

SRB – Notification of Impracticability to include Bail-IN Recognition Clauses in Contracts (here)

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