The AFB is acting as a conduit for feedback and dialogue between member banks and regulators in the policy areas listed below. In some of these areas a member working group (WG) has been formed.
If you are interested in participating in any of our working groups, please contact the Policy and Regulatory Affairs Team.
The terms of reference for our policy working groups can be found here.
Current Policy Initiatives
The AFB has been interacting with policymakers and stakeholders including the PRA and Climate Financial Risk Forum on this topic.
An AFB summary of the CFRF’s 3rd year guides can be read here.
An AFB working group has been formed to feed into discussions and policy matters relating to climate-related risk, and meets quarterly.
This working group was formed following the FCA/PRA Discussion Paper 3/22 – ‘Operational resilience: Critical third parties to the UK financial sector’, as well as HMT’s June Policy Statement on critical third parties.
On July 26 2022, the working group met with the FCA, PRA and HM Treasury at a roundtable to discuss these items. Members can read a summary of the meeting here.
In March 2021 the AFB formed a working group to discuss the Bank of England’s transformation plan. The AFB continues to engage with the BoE and members on this topic.
The working group met on 26 October and is drafting the CP response based on the feedback.
In December 2022 the AFB sent a position paper ‘The Replacement of Retained EU Law and Changes to the UK Regulatory Framework’, prepared with Allen & Overy, to HM Treasury.
On 11 July 2023 HMT published ‘Building a Smarter Financial Services Regulatory Framework for the UK: HM Treasury’s Plan for Delivery’, which outlines the approach to the repeal/replacement of EU retained law, including the balance of responsibilities between HMT and the regulators, and the Government’s legislative approach.
AFB will continue to advocate on this topic with relevant stakeholders.
In 2020 the AFB became a partner member of the Financial Services Skills Commission (FSSC), which aims to ensure that the financial services sector has the talent and skills it needs for the future. This working group also receives quarterly updates on the work of FSSC (latest edition here).
In October the AFB submitted a response to the PRA’s CP6/22 on Model Risk Management Principles for Banks. In December we hosted a virtual member roundtable with the PRA policy team.
In September 2023 we held a virtual seminar with KMPG on the final proposals in PRA PS1/21, which also included a presentation on the results of an AFB member survey (conducted in Spring 2023 and answered by 27 member banks) on the proposals.
We will continue to engage with the PRA on MRM throughout 2024.
An AFB working group has been formed to feed into discussions and policy matters relating to Money Laundering Reporting in the UK, as well as (since February 2022) the implementation of sanctions against Russia. The AFB is interacting with policy makers and stakeholders, including the FCA, HMT and OFSI, on this topic.
The working group has submitted responses to a number of consultations, including the HMT Consultations on ‘Amendments to the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017′ and on the review of the UK’s AML/CTF regulatory and supervisory regime, as well as engaging on the HMRC and Companies House Register of Overseas Entities discrepancy reporting guidance.
The working group was initially formed in response to PRA and FCA consultation papers on operational resilience and outsourcing. The WG continues to feed into discussions and policy matters on these topics.
On 25 May 2022, the PRA held a roundtable for working group members to discuss the implementation of the operational resilience and outsourcing requirements (summary here).
The AFB formed a working group to respond to the Discussion Paper (here), with a Consultation Paper on the first layer of the new regime, CP5/22 – ‘The Strong and Simple Framework: A Definition of a Simpler-regime Firm’, published on 29 April 2022.
AFB continues to engage with the PRA and members on the topic.
Following interest from members, the AFB undertook a survey on the operational impact of the points-based immigration system.
In May 2022, the AFB published its position paper ‘The Operational Impact of the UK’s Immigration System’ (here) based on the survey and follow-up interviews with members.
In June 2022, the AFB sent a two-page letter to the Home Office and HM Treasury regarding meaningful amendments to the UK’s immigration system (here).
In October 2022 the AFB held an in-person roundtable where a group of members discussed their experiences of the UK Visa system and the procedures banks have for bringing staff to the UK from overseas for business purposes. A summary can be read here.
An initial Working Group meeting was held in January 2023 to discuss the current operation of the SM&CR, and areas that could be reviewed, following the publication of the Edinburgh Reforms in December 2022.
AFB considered the feedback raised, and outlined some general comments in a letter to HM Treasury on 6 February (here).
On 1 June 2023, AFB responded to both the HMT CfE (here) and FCA/PRA DP1/23 (here).
We await further details of the regulators’ proposals in the forthcoming consultation paper, and feedback from HMT’s Call for Evidence.
Past Policy Initiatives
Below is a selection of policy initiatives and working groups which were previously active.
Following the publication of the European Commissions’ proposals on Third Country Branches in October 2021, the AFB met with interested members and submitted a paper to the European Commission in February 2022.
In H1 2021, 25 AFB members were interviewed about their cyber risk governance practices for an AFB report, produced with Marsh.
The AFB continues to feed into discussions and matters relating to cyber risk governance with the FCA, PRA and Bank of England.
In advance of Phase 5 of the European Market Infrastructure Regulation (EMIR) implementation of margin requirements, the AFB interacted with both the PRA and FCA to assist firms with the implementation.
An AFB working group responded to FCA CP20/20, which set out the FCA’s proposed approach to international firms providing or seeking to provide financial services that require authorisation. The FCA published their final rules in February 2021 and the AFB continued to liaise with members and the FCA on this topic.
On 12 August 2022, FCA has now announced that all firms in the Temporary Permissions Regime that it is expecting to apply for full authorisation in the UK should now have received a formal direction confirming their ‘landing slot’ (here).
The AFB LIBOR Transition Working Group was formed to discuss and feed into policy matters relating to LIBOR Transition.
An AFB working group was formed to respond to PRA CP2/21, which discussed the PRA’s approach to the future supervision of international banks. Supervisory Statement 5/21 took effect from 26 July 2021.
An AFB working group, formed in late 2019, led the work to update Part II/Sector 15 (Trade Finance) of the JMLSG guidance, which was approved in October 2021.
An AFB working group responded to HM Treasury’s Future Regulatory Framework Review and AFB also submitted a response to the further consultation on the FRF Review in February 2022.
AFB engaged HMT and the regulators throughout the progress of the Financial Services and Markets Bill, which became the FSM Act 2023 on 29 June 2023.
Contact the Policy & Regulatory Affairs Team
To find out more about the work of the Policy and Regulatory Affairs team, or to discuss how you can provide input, please contact us.Contact Policy & Regulatory Affairs Team