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In part five of our Success Series over-regulation white paper, we look at proposed solutions to assist the banking sector in implementing changes required following the biggest reforms imposed to the sector in a generation.
CONSEQUENCES AND CHALLENGES FOR BANKS
MINIMISING BUSINESS DISRUPTION
While there is a tremendous increase in regulatory activity, there is no specific framework for companies to follow in developing their regulatory response. Instead, companies should seek to create a new strategic framework of their own which would bring order and structure to the process. There are multiple global regulations seeking to achieve similar objectives but working on different timelines. Most organisations focus primarily on the differences across the regulatory landscape. Identifying commonalities will prove helpful to banks first by identifying the regulatory elements common to various requirements across relevant geographies and addressing them through an integrated approach to avoid reworking, confusion and unnecessary costs. PRIORITISING INVESTMENT IN RESOURCE AND TRAINING Many banks will be putting large scale change programmes in place over the next two years to be compliant with and responsive to the regulations. However, as discussed in this paper, regulatory requirement will, by definition, make some parts of the business more costly and/or less profitable over time. Many banks will be putting large scale change programmes in place over the next two years to be compliant with and responsive to the regulations. However, regulatory requirement will make some parts of the business more costly and/or less profitable over time. The key to successful change programmes is to determine in which parts of the business the bank wants to remain (with the regulatory impact incorporated) and steer toward that future. It is highly unlikely banks will be able to keep the same business model and simply plan on absorbing the impact of the new regulations. Banks should also institutionalise capital performance measures within their business strategy if they are to support the overall success of such response programmes. REDUCED RETURNS ON CAPITAL The cost of compliance is high and increasing rapidly, but those organisations that institute a centralised, strategic regulatory response programme will have more control over managing and optimising their investment in compliance. While banks recognise the importance of such programmes they will need a clear C-level executive sponsor for their regulatory response programme. Organisations will need to demonstrate the necessary rigour and commitment to ensure the change programme stays on course and delivers more than basic compliance. IMPACT ON PROFITABILITY ON A RISK-ADJUSTED BASIS The introduction of so many new regulations means that banks will have to set priorities in order to be effective in terms of their responses. There are simply not enough resources, time, money or people to address every tactical aspect of every regulation. There are simply not enough resources, time, money or people to address every tactical aspect of every regulation. The introduction of so many new regulations means that banks will have to set priorities in order to be effective in terms of their responses. There are simply not enough resources, time, money or people to address every tactical aspect of every regulation. A coordinated response also requires an assessment of the impact of regulations on each area of the business. For example, the Basel III/Capital Requirements Directive (CRD) IV provisions addressing capital requirements have a high potential impact on derivative transactions in particular, where higher levels of capital will need to be held to deal with the creditworthiness of the counterparties also known as the CVA charge. However, syndicated lending will experience relatively low impact since minimal funding is required, which can potentially be incorporated within the pricing. Eric Bigham - New High Impact Framework In many cases, financial institutions have a raft of options regarding the implementation of responses to these new regulations. These options range from basic compliance to a comprehensive, optimised outcome which uses the regulatory response as a lever to make the needed changes to the business model. Banks should understand this concept and make deliberate decisions about the trade-off between compliance costs and the costs of achieving an optimised state across the spectrum of required regulatory changes with the support of the business leads for priority strategic system and process enhancements. These choices will not be easy, but banks must establish priorities and determine what resources and funding will be needed to reach these objectives through the appropriate path. CREATE A FRAMEWORK TO TIE REGULATORY REFORM PROGRAMMES TO THE BANK�S OVERALL STRATEGY Ideally, the regulatory response becomes an integral component of the strategy, rather than a standalone initiative. One of the best approaches is likely to be organising complex regulatory demands into common themes for implementation. Next week: Basic Approach Here we conclude the over-regulation white paper in looking at a 4-stage strategy transformation approach that would help banks avoid running duplicating programmes and mitigate the cost of reform. Written by Eric Bigham. Founder and owner of Bigham Consulting.
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