ARTICLE
23 October 2018

UK Prudential Regulator Proposes Period Of Overlap For Transition To New Pillar 2 Reporting Template

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A&O Shearman

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On October 12, 2018, the U.K. Prudential Regulation Authority published a consultation proposing a six-month overlap period following the introduction of the new Pillar 2 Liquidity ...
United Kingdom Finance and Banking

On October 12, 2018, the U.K. Prudential Regulation Authority published a consultation proposing a six-month overlap period following the introduction of the new Pillar 2 Liquidity reporting template (PRA110) from July 1, 2019. The Capital Requirements Directive gives national regulators discretion to set additional Pillar 2 liquidity requirements, to capture those liquidity risks that are either not captured or not fully captured under the Pillar 1 framework. The final element—Pillar 3—involves public reporting of capital. The PRA published its final Policy Statement on the introduction of its Pillar 2 framework in February 2018. The PRA110 template was scheduled to replace the existing "daily flows" and "enhanced mismatch" liquidity reports (FSA047 and FSA048) from July 1, 2019.

Since its Policy Statement, the PRA has reassessed the risks from transitioning to the PRA110 template and considers it prudent to delay the termination of FSA047 and FSA048, to ensure data quality and continuity. The PRA proposes that the PRA110 is introduced on July 1, 2019 as planned. However, between then and January 1, 2020, firms should additionally continue to submit liquidity reports using FSA047 and FSA048. The overlap will allow the PRA and firms alike to assess the quality of PRA110 reporting.

The PRA is inviting comments on the proposal by November 12, 2018. The PRA considers that the short consultation period is justified due to the fact that firms are already reporting using FSA047 and FSA048.

The consultation paper (PRA CP22/18) is available at: https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/consultation-paper/2018/cp2218.pdf  and details of the PRA's Pillar 2  Policy Statement are available at: https://finreg.shearman.com/uk-prudential-regulation-authority-publishes-fin.

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