First up, however, was an old friend from the past – LIBOR. Deutsche Bank was fined a record $2.2bn, fired seven senior executives and perhaps more tellingly admitted to criminal, yes criminal, charges! The fine was imposed by regulators in the US and the UK as it was revealed the extent of the market manipulation in London, Europe and Tokyo. The FCA in the UK and in the US, The Department of Justice, Commodity Futures Trading Commission and New York’s Department of Financial Services imposed the fines. Of particular note is Benjamin Lawsky of NY’s DFS – they fined Deutsche $600m, but more tellingly forced the German Bank to implement an independent monitoring system.
And all this on the back of Deutsche Bank’s operation in the US failing the recent CCAR programme. The cold snaps to hit Boston and New York this winter have abated and the green shoots of spring are appearing – one thing for sure is that it is going to be a long hot, sticky and sweaty summer for the Risk & Compliance teams at the German Bank.
20 years ago (virtually to the day) saw one of the biggest Risk & Compliance failures in our lifetime – the collapse of Barings bank due to a lack of Governance and Control. This was to change (well, supposedly) the way the Financial Services industry was regulated and also ensure that a catastrophe like that could not occur again. Well we know that it did and we know that it could happen again?
That was the Nineties, then came the Noughties (I prefer the Naughties), and now we are in the Teenies. We all know that teenagers need limits and boundaries or they will misbehave. Banks face a number of regulatory compliance challenges these days and the list keeps growing. The vast number of requirements, the time it takes to fully implement some of the rules, and the regulators’ expectations regarding increased data access are placing unprecedented demands on the compliance functions.
As a result of these issues there is a real trend in the industry to establish a central regulatory management office (RMO). We have seen large Finance transformation programmes, then Finance & Risk transformation programmes, then Risk transformation programmes and now ….. Compliance transformation programmes. The role of a central RMO would be to drive consistency and identify common regulatory requirements across the organisation. The ultimate dream to stop those nightmares keeping the CRO and CCO awake at night? A continuous regulatory compliance and control service.
We talk about Black Swan events in Risk Management (events you can never predict). In Compliance, though, the industry cannot afford a Black Ostrich event – burying the head in the sand. We are at the crossroads of economic uncertainty globally, particularly in Europe. God help us if the Federal Reserve ever considered raising interest rates …..
The Return of the King – A New Framework for Market Risk
New regulation is slowly emerging from the sleepy slopes of Basel, which will have the largest impact on market risk calculations since the mid-1990s.
The Fundamental Review of the Trading Book outlines a revised framework and proposes a number of specific measures to calculate Market risk. The scope is wide and covers:
– Reclassification of the definition of the boundaries between the Trading and Banking Book
– Introduction of a mandatory Standardised model
– Improvement in Capital Measures for Internal models approach using Expected Shortfall instead of VaR
– Incremental Default Risk
– Capital add-on related to stress testing and scenario analysis
-Significant increase in the number of simulation runs for Internal Model approval
The full regulations are expected to be implemented in 2017 but there are major implementation issues for Banks with current Internal model Approval. It appears that the rumours of the death of the Quants are very much exaggerated!!!