Added Stress in the United Kingdom

Last week, the Wall Street Journal reported that financial institutions in the UK are being subjected to even more stringent stress testing requirements than their US counterparts. The Financial Services Authority (FSA) is requiring the largest financial institutions to conduct what it calls "reverse stress testing". These tests are designed to determine what an institution will need to recover from a catastrophic operational risk event such as a natural disaster or pandemic. Evidently, the UK bankers are none too pleased with the request according to the following report.

Bankers call it the latest example of regulatory overkill. Executives protest that they are wasting countless hours dreaming up outlandish doomsday scenarios. The chief executive of a major U.K. bank said the tests are predicated on "a massive confluence [of] absurd scenarios" in which executives passively watch events unfold rather than trying to stabilize the situation. Bankers are especially worried that the process could result in them being forced to hold more capital. The FSA said in a planning document that the tests "may result indirectly in changes to the levels of capital held by firms" if the exercise "identifies business model vulnerabilities that have not previously been considered."

An FSA spokeswoman defended the exercise. "It might seem outlandish to them, but the point is that it pushes the business model to the point it collapses," the spokeswoman said. She said the banks also should be evaluating relatively mundane situations like what they would do in the event of a major internal fraud.

What is somewhat surprising by this report is the fact that these financial institutions should have already conducted similar scenario planning and testing as part of the Basel II Capital Accord requirements. However, since the Basel II requirements were largely self-regulated, it appears that the banks did not do their homework the first time around. For those bankers in the US who did not do their homework as well, you might want to get started before the teacher asks for it.

Global Solutions for a Global Problem

Last week, the Wall Street Journal in the United Kingdom published an article featuring the views of Britain's Financial Services Authority Chairman Adair Turner.  Given the continued debate and relative inaction from the U.S. Congress, the thoughts from Lord Turner are particularly refreshing.  Here's what he had to say:

One, finance got too big. "We must be more willing to ask...whether the financial system is delivering its vital economic functions as efficiently as possible, or whether parts of it can, and before the crisis did, swell beyond their economically efficient size," he said in a recent speech.

Two, there was too much debt in the system. "There is a huge bias in the tax system towards debt," he said, largely because companies can deduct interest payments before computing taxable profits. "If we can't change that, then the regulatory approach needs to lean against that."

Three, regulators failed to curb excesses, but politicians hardly encouraged aggressive regulation. The cry for "better regulation" meant less regulation, both in the U.K. and U.S. The diagnosis of Britain's economic woes was that regulation was stifling entrepreneurship, he said.

Four, erecting a wall between ordinary deposit-taking and lending, on one hand, and trading on the other is impractical and unwise. Economies benefit when banks turn loans into securities or hedge their positions -- to a point. But by forcing banks to hold capital in the trading operations to provide thicker cushions to absorb losses -- he calls it "a bias towards conservatism" in trading beyond what is necessary for ordinary banking -- speculative trading will migrate away from banks toward hedge funds and the like, a change Lord Turner welcomes.

Five, for all the angst about the slow pace of post-crisis repair of the financial system, global regulators are making surprising progress toward consensus on a new regulatory regime. "We are attempting in 18 months to do changes far more radical than we did in Basel II that took between 12 and 15 years and dealt with some of the areas which proved to be less important," Lord Turner said, referring to the pact regulators reached in the Basel Committee on Banking Supervision that didn't avoid the crisis. Pushed by the newly empowered Financial Stability Board, the process, he said, "has worked better than I would have expected," he said.

Since the crisis was global in both cause and impact, it is encouraging that some are working towards global solutions to the problem.  As the regulatory reform effort unfolds, the U.S. must ensure that our reforms are aligned with our global partners.

FSA's Financial Risk Outlook for 2009

This week, Britain's primary financial regulator - the Financial Services Authority ("FSA") - issued its Financial Risk Outlook for 2009.  The FSA provided several key messages related to effective risk management.  

1. Senior Management should ensure appropriate risk management is undertaken and that there is a clear understanding of the underlying risks to their business model, particularly risks associated with complex hedging strategies. Firms need to satisfy themselves that key risks are appropriately managed and continually re-assessed as financial market and economic conditions evolve.


2. Stress testing and scenario analysis should form an integral part of firms’ risk management, business strategy and capital planning decisions. It is of particular importance in this unpredictable environment, when the financial sector is vulnerable to further shocks, that firms also consider the implications of deteriorating economic conditions and the long-term viability of and weaknesses present in their business models. In addition, the financial sector and economy will also remain vulnerable to potential shocks, such as a large-scale terrorist attack. Firms should continue to consider such risks in their business planning to ensure effective plans are in place for dealing with these shocks.  


3. Strategies need to be underpinned by strong risk management systems and controls for all areas of risk: credit, market and operational risk; conduct of business risks; compliance with relevant rules, codes and standards; and managing risks of fraud and financial crime.


4. Remuneration policies should be in line with sound risk management. Firms should ensure that staff are not given incentives to pursue higher-risk strategies than are consistent with the firm’s overall risk appetite, undermining the impact of systems designed to control risk to the detriment of shareholders and other stakeholders, including depositors, creditors and ultimately taxpayers.

These are solid principles not only for companies in the UK, but for companies across the globe.  Visit www.WheelhouseAdvisors.com to learn more about how we can help your company Navigate Successfully™.