UK: Financial Regulatory Developments (FReD) – 17 July 2015

HEADLINES

  • EP votes on CMU resolution
  • EBA publishes product governance guidelines
  • FCA publishes mortgage advice review results
  • FCA publishes new enforcement referral criteria
  • FCA consults on NRFB disclosure
  • PRA consults on leverage ratio framework

EUROPEAN UNION AND INTERNATIONAL

Financial Stability Board (FSB)

FSB reports benchmark reform progress: FSB has published an interim progress report on its efforts to reform the major interest rate benchmarks (IBORs), and to develop and introduce alternative near risk-free interest rate benchmarks (RFRs). The report notes:

  • since July 2014, the administrators of the IBORs have all taken major steps in strengthening the benchmarks they administer and other reference rates based on unsecured bank funding costs by underpinning them to the greatest extent possible with transactions data;
  • this progress has included compiling reviews of respective benchmark methodologies and definitions, conducting data collection exercises and feasibility studies, consideration of transitional and legal issues, and broad consultations with submitting banks, users and other stakeholders;
  • jurisdictions beyond those to which the recommendations were originally addressed have also taken steps towards reforming the existing rates in their own jurisdiction; and
  • Official Sector Steering Group (OSSG) members have also made concrete progress in identifying potential RFRs.

The OSSG will continue to monitor progress in implementing FSB's recommendations over the next year ahead, and will prepare an updated progress report for FSB in July 2016. (Source: FSB Interim Interest Rate Benchmark Reform Interim Report)

Contact: Rosali Pretorius or Michael Wainwright

European Commission (Commission)

Working party notes DP importance in MiFID 2 and MAR: A working party on data protection has written to the Commission noting the importance of complying with data protection standards when implementing the revised Markets in Financial Instruments Directive (MiFID 2) and Market Abuse Regulation (MAR) regimes. It notes the particular tensions in respect of record keeping, recording of customer communications, publication of sanctions, protection of reporting persons and data subject rights. (Source: Working Party Notes DP Importance in MiFID 2 and MAR)

Contact: Nick Graham or Danielle Van der Merwe

Commission consults on CRD 4 effects on bank financing: The Commission is consulting on the potential impact of the Capital Requirements Regulation (CRR) and Directive (CRD 4) on bank lending to the economy. The Commission has to report by 2016 on their impact on loans to people, small businesses and long-term financing in infrastructure. To help it prepare its report, the consultation seeks views on many issues, including:

  • to what extent have CRR and CRD 4 affected the level of capital held by banks?
  • are all the new requirements under all circumstances proportionate to the risks they were meant to address?
  • what impact are the rules having on lending to smaller businesses, and to infrastructure projects?
  • could some of the rules be simplified or differentiated by risk or size, without compromising their objectives of financial soundness and stability of banks?

It asks for responses by 7 October. (Source: Commission Consults on CRD 4 Effects on Bank Financing)

Contact: Rosali Pretorius or Michael Wainwright

European Parliament (EP)

EP votes on CMU resolution: EP has voted on an Economic and Monetary Policy Committee (ECON) proposal for resolution to progress the Capital Markets Union (CMU) initiative. ECON wants:

  • CMU building blocks in place by 2018;
  • reliable non-bank sources of business finance working alongside well-established bank financing;
  • cross-border insolvency rules that work, and a recovery and resolution framework for non-banks, in particular central counterparties;
  • high-quality, easily comparable financial information on firms seeking crowdfunding or peer-to-peer loans available across borders;
  • SME-friendly regulatory requirements, involving simple procedures with a proportionate administrative burden; and
  • rules that aim to remove entry barriers for SMEs, improve access to finance for innovative companies and ensure that prudential standards are proportionate to the risks that such companies may cause. MEPs believe that simple transparent and standardised securitisation may be useful for some SMEs.

EP also says it is important that all Member States implement CMU and that there is some degree of standardisation in the financial markets. (Source: EP Votes on CMU Resolution)

Contact: Michael Wainwright or Juan Jose Manchado

European Banking Authority (EBA)

EBA publishes product governance guidelines: EBA has published its final guidelines on product oversight and governance arrangements for retail banking products. The guidelines will apply from 3 January 2017 and will apply to manufacturers and distributors when designing, marketing and selling mortgages, personal loans, deposits, payment accounts, payment services and electronic money. The guidelines cover:

  • for manufacturers:

    • Guideline 1: Establishment, proportionality, review and documentation
    • Guideline 2: Manufacturer's internal control functions
    • Guideline 3: Target market
    • Guideline 4: Product testing
    • Guideline 5: Product monitoring
    • Guideline 6: Remedial action
    • Guideline 7: Distribution channels
    • Guideline 8: Information for distributors
  • for distributors

    • Guideline 9: Establishment, proportionality, review and documentation
    • Guideline 10: Distributor's governance
    • Guideline 11: Knowledge of the target market
    • Guideline 12: Information and support for the manufacturer's arrangements.

The guidelines also address outsourcing, reminding firms they should comply with the Committee of European Banking Supervisors' guidance, and that senior management of the outsourcing institution will retain responsibility for compliance. EBA stresses that manufacturers should periodically assess (i) that the internal product oversight and governance arrangements are being duly complied with, (ii) that the internal arrangements are still valid and up to date and (iii) whether the specifications of particular products continue to meet the interests, objectives and characteristics of the target market for which they were designed. Distributors should comply with the product oversight and governance arrangements of the manufacturer that related to bringing products to the market. Distributors should know and recognise the target market for which the product was designed and should normally sell and offer the product only to end-consumers in that target market. They would need to be able to justify selling the product to any other customer. (Source: EBA Publishes Product Oversight Guidelines)

Contact: Michael Wainwright or Nicholas Ralph

EBA issues group support standards: EBA has published final draft regulatory technical standards (RTS) and guidelines on the provision of group financial support, as well as final draft Implementing Technical Standards (ITS) detailing the disclosure requirements of these activities. The RTS and guidelines establish a harmonised regulatory framework designed to facilitate the provision of intra-group financial support across the EU under the Bank Recovery and Resolution Directive. EU regulators will grant authorisation for support on the basis of a number of conditions, including the:

  • interest of the group as a whole and the risks in the absence of the support;
  • expected success of the support;
  • terms of the support;
  • possible impact on financial stability; and
  • resolvability of the providing entity.

Regulators will assess applications on the basis of the capital and liquidity situation of the relevant institution. (Source: EBA Streamlines Intra-group Financial Support for Banking Institutions)

Contact: Rosali Pretorius or Michael Wainwright

EBA updates single rulebook Q&As: EBA has updated its single rulebook Q&As to include seven new items. (Source: EBA Single Rulebook Q&As)

Contact: Rosali Pretorius or Michael Wainwright

EBA updates on transparency and stress tests: EBA has published a sample of banks taking part in the 2015 transparency exercise, together with the draft templates illustrating the type of data for disclosure. It also released the key features and a tentative calendar for the 2016 EU-wide stress test. The 2016 exercise will be based on a constrained bottom-up approach and will be closely aligned with the cycle of the annual supervisory review and evaluation process (SREP). EBA will discuss the draft methodology and templates with relevant stakeholders before the end of 2015 and expects to launch the 2016 exercise in the first quarter of 2016, and to publish the results in Q3 2016. (Source: EBA Updates on Upcoming Transparency Exercise and on Key Features of 2016 EU-wide Stress Test)

Contact: Rosali Pretorius or Michael Wainwright

EBA publishes risk mitigation responses: EBA has published the responses to its consultation on RTS on risk mitigation techniques for OTC derivatives not cleared by a central counterparty (CCP). (Source: RTS on Risk Mitigation Techniques for OTC Derivatives Not Cleared by a CCP)

Contact: Rosali Pretorius or Michael Wainwright

European Insurance and Occupational Pension Authority (EIOPA)

EIOPA issues Solvency 2 disclosure note: EIOPA has issued a note on solvency and financial condition and the potential role of external audit under Solvency 2. The note emphasises the need for high-quality public information and the relevant use of external audit services. EIOPA will be evaluating the implementation of Solvency 2 public disclosure and will consider taking regulatory action where any disclosures fall below the high standard it expects. (Source: EIOPA Calls for High-Quality Public Disclosure Under Solvency 2)

Contact: Michael Wainwright or Juan Jose Manchado

Euro Retail Payments Board (ERPB)

ERPB issues post-meeting statement: ERPB held its third meeting on 29 June. Among other things, the meeting addressed:

  • instant payments in euro: ERPB determined that, irrespective of the payment instrument on which they are based, instant payment solutions offered to end-users in euro should be developed at the pan-European level or, if developed at the national level, should at least be interoperable with those solutions based on the same payment instrument;
  • person-to-person (P2P) mobile payments: any person should be able to initiate a pan-European P2P mobile payment safely and securely, using a simple method with information the counterparty is prepared to share in order to make a payment, using existing infrastructure as far as possible;
  • recommendations on technical standards related to payment cards: there will be technical standards for payment cards in the EU; and
  • electronic invoicing solutions related to retail payments: ERPB endorsed the objective of a harmonised electronic invoice/bill presentment and payment service for payers and payees, and an electronic invoicing/billing network for payees to reach all consumers and businesses in Europe.

(Source: Statement Following the Third Meeting of ERPB Held on 29 June 2015)

Contact: Nicholas Ralph or Josie Day

European Systemic Risk Board (ESRB)

ESRB responds on clearing obligation: ESRB issued a response to ESMA's consultation on the clearing obligation for other OTC interest rate derivatives. The response outlines:

  • ESRB's stance on the use of central counterparties;
  • an assessment of ESMA's analysis and additional data/information; and
  • ESRB's conclusions and proposals.

(Source: ESRB Response to ESMA Consultation Paper No. 4 on the Clearing Obligation for Other OTC Interest Rate Derivatives)

Contact: Rosali Pretorius or Tom Harkus

Agency for the Cooperation of the Energy Regulators (ACER)

GFMA and ISDA submit REMIT questions: The Global Financial Markets Association (GFMA) and International Swaps and Derivatives Association (ISDA) have written to ACER with a number of questions regarding the Regulation on Wholesale Energy Market Integrity and Transparency (REMIT). Specifically they ask for:

  • clarification on the scope of the obligation for Organised Market Places to offer a data reporting agreement "at the request of the market participant";
  • further clarification or guidance on the territorial scope of the reporting regime;
  • clarification as to whether specific (listed) types of contract and event are within scope for the reporting regime. They request that ACER produce a document along the lines of the Q&A published by ESMA in relation to the reporting obligation under EMIR; and
  • alterations to the format of the requirements in a handful of instances.

(Source: Questions to ACER on REMIT Implementation From GFMA and ISDA GFMA and ISDA Submit Comments to ACER on REMIT Implementation)

Contact: Luca Salerno or Tom Harkus

UK GOVERNMENT AND PARLIAMENT

Bank of England (BoE)

BoE responds on interoperability: BoE has published its policy response on implementing ESMA's Guidelines and Recommendations on CCP interoperability arrangements. The final standards BoE will normally apply as a minimum when assessing CCP interoperability arrangements relate to:

  • level of inter-CCP margin;
  • source of inter-CCP margin;
  • CCP default resources other than inter-CCP margin;
  • loss allocation rules and post-default arrangements; and
  • interoperability for derivatives products.

(Source: BoE Responds on Interoperability)

Contact: Rosali Pretorius or Tom Harkus

Treasury updates sanctions: Treasury has updated the sanctions lists in respect of South Sudan. (Source: Treasury Updates Sanctions)

Contact: Emma Radmore or Tom Harkus

UK FINANCIAL SERVICES AND MARKETS REGULATORS

Financial Conduct Authority (FCA)

FCA publishes mortgage advice review results: FCA has published the results of its review of advice and distribution under the Mortgage Market Review (MMR). It looked at the quality of advice provided by lenders and intermediaries and was generally pleased with the findings. It noted that:

  • many lenders have taken significant steps to provide advice for the first time. These firms, and those that have always provided advice, should now focus on delivering consistently good outcomes for customers. The report identified that some firms relied on highly structured processes which made communication with customers stilted, inflexible and unsatisfactory for customers. On the other hand, some had no structure, which meant outcomes for customers could be inconsistent and it was hard to show what steps firms had taken to ensure suitability;
  • there was no evidence of systemic customer detriment;
  • some firms were not taking reasonable steps to get sufficient, relevant information about customers' needs and circumstances before making recommendations;
  • 59% of advice was assessed as suitable but the basis for 38% of recommendations was unclear. In 19% of the mystery shops FCA carried out, customers thought they had received a recommendation but in fact there had been no advice.

Accompanying consumer research highlighted that some customers place the greatest importance on the initial monthly payment to the detriment of other factors. Generally, customers did not appreciate the value and importance of advice, and did not separate it from the rest of the mortgage buying process. FCA is engaging with firms where it found problems and will continue to encourage good practices within the sector. In general, it expects:

  • firms to consider whether they need to take steps to improve how they communicate with customers when providing mortgage advice or information;
  • advisers to take reasonable steps to establish customers' needs and circumstances when giving advice and making recommendations;
  • firms to review whether their practices have the potential to create unintended consequences that can lead to poor customer outcomes; and
  • where appropriate, senior managers and board members to ensure the firm has appropriate controls and reporting mechanisms to demonstrate it acts in accordance with the best interests of its customers.

(Source: FCA Publishes Mortgage Advice Review Results)

Contact: Nicholas Ralphor Emma Radmore

FCA publishes new enforcement referral criteria: FCA has published an update to the criteria it uses when deciding whether to refer matters to enforcement, and clearer explanations of how it uses them. It will use the criteria when the potential outcome of an investigation might be to (i) take disciplinary action to fine, publicly censure, suspend and/or restrict firms/individuals or (ii) make a prohibition order. FCA has clarified how it assesses the three overarching questions it asks, which are:

  • is an enforcement investigation likely to further FCA's aims and statutory objectives?
  • what is the strength of the evidence and is an enforcement investigation likely to be proportionate?
  • what purpose or goal would be served if FCA were to take enforcement action in this case?

The clarifications follow a Treasury recommendation in December 2014, and FCA will consult later in the year on other elements of Treasury's request. (Source: FCA Publishes New Enforcement Referral Criteria)

Contact: Felicity Ewing or Katharine Harle

FCA makes new rules: During June and early July, FCA has made several minor changes to its rules:

  • the Periodic Fees (Pension Guidance Providers) Instrument 2015 amends the Glossary and Fees Manual from 19 June. It puts in place the framework for raising the pensions guidance providers levy and sets the amount payable by each designated pensions guidance provider in 2015/16;
  • the Periodic Fees (2015/2016) and Other Fees Instrument 2015 amends various chapters of the Fees Manual, also from 19 June in respect of FCA, Financial Ombudsman Service (FOS) and Money Advice Service fees and the pensions guidance levy;
  • the Fees (Consumer Buy to Let) Instrument 2015 also amends the Glossary and Fees Manual from 19 June in respect of application fees for applicants to undertake consumer buy-to-let related activities in 2015/16 and puts in place a framework for FCA and FOS periodic fees and levies for 2016/17;
  • the Handbook Administration (No 38) Instrument 2015 makes minor amendments to several modules of FCA's Handbook, mainly from 1 August;
  • the Individual Accountability Instrument 2015 amends the Glossary, parts of the Senior Management Arrangements, Systems and Controls Sourcebook, the Fit and Proper Test for Approved Persons and the Supervision Manual, and introduces the new Code of Conduct (COCON). It implements FCA rules on the Senior Manager Regime (SMR). The changes take effect partly on 13 July 2015, partly on 7 March 2016 and the remainder on 7 March 2017; and
  • the ADR Directive Supplementary Instrument 2015 is an FOS instrument amending the Glossary and Dispute Resolution Sourcebook to ensure consistency with the Alternative Dispute Resolution (ADR) Directive. The changes take effect from 9 July.

(Source: Handbook Notice 23)

Contact: Emma Radmore or Nicholas Ralph

FCA consults on NRFB disclosure: FCA is consulting on disclosures to consumers by "non-ring-fenced bodies" (NRFB). An NRFB is a deposit-taker that is not a ring-fenced body (RFB), or is exempt from ring-fencing. FCA must make rules specifying the information that an NRFB must provide to individuals with financial assets of at least £250,000 that are account holders or that have applied to open an account, including joint accounts, with an NRFB. NRFBs will have to give the relevant consumers descriptions of the investment and commodities trading activities that they carry out, and details of any "prohibited actions". FCA says its proposals do not go significantly beyond the requirements of the law, except in relation to timing of information provision. FCA says firms will usually provide the information before they become NRFBs, and, once the regime is in force in 2019, when an individual applies to open an account with an NRFB. NFRBs will have to give out explanatory information to help consumers to understand the implications of banking with a non-ring-fenced entity in the group, and display up-to-date information on their website. FCA does not plan any requirements on banks that are not subject to the ring-fencing regime. FCA asks for comment by 13 November. (Source: FCA Consults on NRFB Disclosure)

Contact: Michael Wainwright or Tom Harkus

FCA speaks on accountability: Martin Wheatley spoke on preparing to implement the SMR. He explained the background and the basic structure, and the need for firms' executive bodies to be fully engaged. He noted concerns that firms would need to register too many people. He said he expects that only the most senior people will need to be registered, and FCA will push back on firms that it feels are seeking to register too many individuals. He discussed measures the regulators have taken to address other concerns and said FCA is preparing its feedback on the presumption of responsibility. He said firms must remember the ultimate test is about reasonable standards. (Source: FCA Speaks on Accountability)

Contact: Richard Caird or Katharine Harle

FCA speaks on FEMR: Tracey McDermott has spoken to the International Capital Market Association (ICMA) on the Fair and Effective Markets Review (FEMR). She addressed the focus and findings of the review, and moved on to discuss the SMR and current initiatives that will address some of the FEMR recommendations. She also provided information on the role of the proposed FICC (Fixed Income, Currency and Commodity) Standards Board. (Source:FCA Speaks on FEMR)

Contact: Michael Wainwright or Nicholas Ralph

FCA publishes competition powers guidance: FCA has published its final form guidance on how it will use its concurrent competition powers with the Competition and Markets Authority (CMA). The new powers came into force on 1 April and FCA the ability to enforce against infringements of competition law, additional powers to conduct market studies and powers to refer markets to CMA – which can also exercise the powers. (Source: FCA Publishes Competition Powers Guidance)

Contact: Alex Haffner, Rebecca Owen-Howes or Richard Jenkinson

Prudential Regulation Authority (PRA)

PRA consults on leverage ratio framework: PRA is consulting on how it will meet the Financial Policy Committee (FPC) direction of 1 July to implement a UK leverage ratio framework. PRA proposes that firms in scope (that is, PRA-regulated banks and building societies with consolidated retail deposits equal to or greater than £50 billion) must meet a minimum leverage ratio requirement. They will also need to consider whether they hold an amount of Common Equity Tier 1 that is greater than or equal to their countercyclical leverage ratio buffer (CCLB), and, if the firm is a Global Systemically Important Institution (G-SII), their G-SII additional leverage ratio buffer (ALRB). Firms will have to report and disclose an averaged leverage ratio by applying daily averaging to on-balance sheet exposures and monthly averaging to the capital measure and off-balance-sheet exposures. PRA proposes the framework should take effect from 1 January 2016 but there will be a transitional period of 12 months for firms to comply with the averaging requirement. The consultation includes:

  • proposed rules on (i) the UK minimum leverage ratio and buffers, (ii) UK leverage ratio reporting and (iii) UK leverage ratio disclosures;
  • draft supervisory statements setting out (i) PRA's expectations in relation to the application of the UK leverage ratio framework and (ii) the basis on which firms would be expected to report leverage ratio information required under the UK leverage ratio framework; and
  • proposed reporting and transitional reporting templates.

PRA asks for comments by 12 October 2015, particularly on the reporting and disclosure requirements and providing an analysis of firms' incremental compliance costs as a result of complying with the averaging requirements. (Source: PRA Consults on Leverage Ratio Framework)

Contact: Rosali Pretorius or Tom Harkus

PRA speaks on Solvency 2: Sam Woods, speaking to the Association of British Insurers, focused on:

  • "busting the myth" that there is some kind of plan to use Solvency 2 to increase required capital across the insurance sector;
  • similarly, allaying industry suspicion that the current ICAS regime for capital adequacy will remain after January 2016; and
  • making clear firms who wish to make use of transitional measures will be given the freedom to do so.

(Source: PRA Speaks on Solvency 2)

Contact: Michael Wainwright or Juan Jose Manchado

PRA issues LTV and DTI statement: PRA is consulting on how it intends to implement directions of the Financial Policy Committee (FPC) on loan to value (LTV) and debt to income (DTI) ratio limits for owner-occupied mortgages. When FPC makes use of its powers, PRA expects to base its approach as far as possible on the framework established to implement FPC's 2014 recommendation on loan to income ratios in mortgage lending. PRA plans to consult when implementing an FPC Direction and will then explain the exact implementation approach in more detail. PRA invites any comments by 12 October. (Source: PRA's Intended Implementation Approach to FPC Directions on LTV and DTI Ratio Limits)

Contact: Nicholas Ralphand Josie Day

PRA updates on Solvency 2: PRA has updated on Solvency 2 implementation, outlining recent publications from both itself and EIOPA. (Source: PRA Updates on Solvency 2)

Contact: Michael Wainwright or Juan Jose Manchado

Financial Ombudsman Service (FOS)

FOS consults on ADR amendments: FOS has published a consultation on changes to its rules to take account of implementation of the new alternative dispute resolution (ADR) regime. It is a short consultation, asking for comment by 20 July. (Source: FOS Consults on ADR Amendments)

Contact: Nicholas Ralphor Tom Harkus

Payment Systems Regulator (PSR)

PSR appoints PSF chair: PSR has appointed Ruth Evans, currently chair of the Authority for Television on Demand, as chair of the Payments Strategy Forum (PSF). She takes up the role on 27 July. PSR has also issued a call for members to find 20 individuals in senior positions to populate the forum, which is due to meet for the first time in autumn 2015. (Source: PSR Appoints Ruth Evans as Chair of the Payments Strategy Forum)

Contact: Michael Wainwright or Josie Day

Financial Services Compensation Scheme (FSCS)

FSCS issues SCV guide: In light of changes brought about by the adoption of the Recast Deposit Guarantee Schemes Directive (DGSD2), FSCS has issued a detailed guide to its single customer view (SCV). The guide sets out changes relating to a wide range of areas including reporting requirements; SCV file structure; depositor, address and account details; eligibility; balance calculations and exclusions. The majority of changes take effect in December 2016, but firms already subject to SCV requirements will need to make some minor adjustments from 3 July 2015 to support DGSD2 requirements. (Source: FSCS Guide to SCV)

Contact: Nicholas Ralphor Josie Day

Advertising Standards Agency (ASA)

ASA rules Direct Line Landlord Insurance ad misleads: ASA has ruled that a radio advertisement advertising Direct Line Landlord Insurance was misleading as it appeared to treat landlords as synonymous with freeholders. This was an issue because the "boiler cover as standard" mentioned in the advertisement was only open to those who purchased the buildings insurance element of the Landlord Insurance, something that a leaseholder landlord was unlikely to do. ASA reached its verdict on the basis that the requirement for buildings insurance was important and so its brief mention at the end of the advertisement was insufficient. (Source: ASA Ruling on UK Insurance Ltd (Direct Line))

Contact: Emma Radmore or Josie Day

OTHER REGULATORS/AUTHORITIES/INDUSTRY ASSOCIATIONS

Bank for International Settlements (BIS)/Basel Committee on Banking Supervision (Basel Committee)

CPMI and IOSCO begin PFMI Principles assessment: The Committee on Payments and Market Infrastructures (CPMI) within BIS and the International Organisation of Securities Commissions (IOSCO) have started the first Level 3 assessment of the implementation of the Principles for Financial Market Infrastructures (PFMI). The review will:

  • examine the level of consistency in the outcomes of PFMI Principles implementation as part of CPMI-IOSCO's monitoring of full, timely and consistent implementation of the PFMI;
  • focus on a subset of requirements under the PFMI that relate to financial risk management by CCPs including certain practices related to governance, stress-testing, margin, liquidity, collateral and recovery;
  • consider outcomes achieved in the above by examining a number of globally- and locally-active CCPs that clear derivative products; and
  • inform CPMI and IOSCO about the nature and potential causes of variations in approaches or outcomes.

The review will report in 2016. (Source: CPMI and IOSCO Begin First "Level 3" PFMI Principles Assessment)

Contact: Rosali Pretorius or Michael Wainwright

Basel Committee reports on supervisory colleges progress: The Basel Committee has published a report on the implementation of principles for effective supervisory colleges. Conclusions include:

  • supervisors feel the functioning of supervisory colleges has improved;
  • colleges play a key role in assisting supervisors;
  • colleges have evolved into key forums for discussion of broader issues, which is very helpful;
  • a wide range of college structures has been developed, with greater attention to host regulator concerns;
  • the collaborative work among college members contributes to improving the effectiveness of the oversight of cross-border banking groups;
  • while supervisors report that interaction with firms has improved in supervisory colleges, particularly in terms of a higher-quality engagement with management, many firms have indicated that they would like to receive more feedback on college discussions; and
  • the greatest challenges for colleges are around crisis management.

(Source: Progress Report on the Implementation of Principles for Effective Supervisory Colleges)

Contact: Rosali Pretorius or Michael Wainwright

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Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.