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    内容提示: Published on 8 November 2011 by authority of the House of Commons London: The Stationery Office Limited House of Commons Treasury Committee Accountability of the Bank of England Twenty-first Report of Session 2010–12 Volume II Additional written evidence Ordered by the House of Commons to be published 19 October 2011 The Treasury Committee The Treasury Committee is appointed by the House of Commons to examine the expenditure, administration, and policy of HM Treasury, HM Revenue and Customs...

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    Published on 8 November 2011 by authority of the House of Commons London: The Stationery Office Limited House of Commons Treasury Committee Accountability of the Bank of England Twenty-first Report of Session 2010–12 Volume II Additional written evidence Ordered by the House of Commons to be published 19 October 2011 The Treasury Committee The Treasury Committee is appointed by the House of Commons to examine the expenditure, administration, and policy of HM Treasury, HM Revenue and Customs and associated public bodies. Current membership Mr Andrew Tyrie MP (Conservative, Chichester) (Chairman) Tom Blenkinsop MP (Labour, Middlesbrough South and East Cleveland) John Cryer MP (Labour, Leyton and Wanstead) Michael Fallon MP (Conservative, Sevenoaks) Mark Garnier MP (Conservative, Wyre Forest) Stewart Hosie MP (Scottish National Party, Dundee East) Andrea Leadsom MP (Conservative, South Northamptonshire) Mr Andy Love MP (Labour, Edmonton) John Mann MP (Labour, Bassetlaw) Mr George Mudie MP (Labour, Leeds East) Jesse Norman MP (Conservative, Hereford and South Herefordshire) David Ruffley MP, (Conservative, Bury St Edmunds) John Thurso MP (Liberal Democrat, Caithness, Sutherland, and Easter Ross) Mr Chuka Umunna MP (Labour, Streatham) was also a member of the Committee during the inquiry. Powers The committee is one of the departmental select committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No 152. These are available on the Internet via www.parliament.uk. Publication The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the Internet at www.parliament.uk/treascom. The Reports of the Committee, the formal minutes relating to that report, oral evidence taken and some or all written evidence are available in printed volume(s). Additional written evidence may be published on the internet only. Committee staff The current staff of the Committee are Chris Stanton (Clerk), Lydia Menzies (Second Clerk), Jay Sheth, Peter Stam, Antonia Brown and Renée Friedman (Committee Specialists), Phil Jones (Senior Committee Assistant), Steven Price and Baris Tufekci (Committee Assistants) and Nick Davies (Media Officer). Contacts All correspondence should be addressed to the Clerk of the Treasury Committee, House of Commons, 7 Millbank, London SW1P 3JA. The telephone number for general enquiries is 020 7219 5768; the Committee’s email address is treascom@parliament.uk List of additional written evidence (published in Volume II on the Committee’s website www.parliament.uk/treascom) Page 1 Intellect Ev w1 2 Aviva Ev w5 3 British Bankers’ Association Ev w6 4 Forum for Stable Currencies Ev w10 5 Building Societies Association Ev w14 6 Financial Services Consumer Panel Ev w17 7 Financial Services Practitioner Panel and Smaller Businesses Practitioner Panel Ev w20 8 Association for Financial Markets in Europe Ev w22 9 Professor Forrest Capie, Official Historian, Bank of England Ev w24 cobberPack: UPL: CWE1 [SO]Processed: [03-11-2011 13: 30]Job: 012044Unit: PG01Treasury Committee: EvidenceEv w1Written evidenceWritten evidence submitted by IntellectExecutive SummaryAs HM Government has set out in its recent Growth Strategy, “the private sector cannot plan for the futureif it does not have confidence in the long-term stability of the economy”—the requirement for this growthstrategy was, after all, a direct result of the failure of the financial system in 2008.Since then, significant efforts have been made by regulatory authorities on a global basis to address theissues posed by the banking crisis. In the UK, HM Treasury, the Independent Commission on Banking, theFinancial Services Authority, Bank of England and of course the Treasury Select Committee have all dedicatedsignificant time and resource to identifying and addressing priority issues in order to reduce the possibility(and potential impact) of another crisis.As it stands however, there is a crucial oversight in these ongoing reforms—specifically relating to systemicrisk. The systems and processes for the Bank of England to collate the necessary information from SystemicallyImportant Financial Institutions (SIFIs) that can then be used to identify the build up of risk across the wholeof the financial system are not in place. If financial stability cannot be guaranteed because the means to spotthe next banking crisis are not in place how, therefore, can long term economic growth be assured?This inability to monitor systemic risk is one of the major contributory factors behind the massive publicspending cuts that we are all now facing—it is why front line services are being cut for ordinary citizens andwhy a number of industries are facing very damaging reductions in their public sector revenues over the comingyears. Simply put, banking institutions cannot be bailed out to the tune of £1.3 trillion without consequences. Itis unlikely that in the event of another financial crisis, which given the current tools that are available forregulators will be again largely unseen before it is too late, such bail outs will be possible given the state ofthe public purse.Therefore it is essential that the Bank of England be given the appropriate tools to undertake its crucialfinancial stability role.In both the US and Europe, this gap in the regulators tool-set has been acknowledged and steps have beentaken to allow regulatory authorities to build a single view of risk across the system, yet in the UK we arelagging behind, relying upon the assumption that such a system is already in place. As we still have the samesystem with the same lack of granular data as before the financial crisis, this is not the case.Intellect, as the trade association for the UK technology industry, believes that the Bank of England thereforemust firstly make an effort to identify what system-wide information would allow it to spot the build up ofrisk and intervene, before it is too late. Secondly it must advocate an industry-funded “systemic risk utility”—an early warning system—that would draw standardised and detailed data from across financial institutions andpresent it as a “dashboard” so the Financial Policy Committee can make the appropriate decisions to safeguardfinancial stability.1. Intellect Financial Services Programme1.1 Intellect is the UK trade association for the IT, telecoms and electronics industries. Our members accountfor over 80% of these markets and include blue-chip multinationals as well as early stage technologycompanies, and play a crucial role in virtually every aspect of our lives. In the UK these industries togethergenerate around 10% of GDP and 15% of trade, directly employing over one million people.1.2 We are a trusted partner for Government, both in terms of policy development and policy implementationacross numerous sectors. We look to ensure that all relevant engagement of policymakers and regulators withindustry is both easy and as valuable as possible in order that the technology industry may play the fundamentalrole it merits in the success of UK plc.1.3 Intellect’s Financial Services Programme brings together over 150 suppliers of information systems,services and consultancy to the financial services sector. After the public sector, the financial services industryrepresents the largest market place for many of Intellect’s members. From software companies to serviceproviders, enabling trading platforms and payment processing, technology is crucial to the sector. As such, theindustry’s regulatory regime is a key issue, as, in many cases, it will be our members working with the financialinstitutions to ensure compliance. Global IT service providers sit alongside many specialised smaller companiesand all play an active role in imparting their expertise and experience to better inform the development offinancial services policy at a cross roads in the industry’s development.1.4 Many of Intellect’s members are heavily involved in providing the fundamentally important technologyplatforms upon which the UK’s financial services industry is built. For example, these members help facilitatethe 5.7 billion automated payments that are made through the banking system on an annual basis. Indeed,through Intellect our members are working with the Payments Council to develop the future technology thatwill afford consumers and businesses alike more convenient, secure and efficient ways to conduct their cobberPack: UPL: CWE1 [E]Processed: [03-11-2011 13: 30]Job: 012044Unit: PG01Ev w2Treasury Committee: Evidencetransactions. Similarly, the 40 million online bank accounts that are registered in the UK would not functionwithout the technological capability that our members design and supply.2. What Resources does the Bank of England Require to Carry Out its Functions?Systemic risk “early warning system”2.1 Intellect believes that there should be a much greater focus now on the tools required for the Bank ofEngland to carry out its financial stability role and specifically relating to its newly designated responsibilityto monitor the build up of systemic risk and act accordingly to mitigate it. As it stands, the Bank of Englanddoes not currently have the tools to undertake this role effectively and there is an assumption that the toolsthat are in place, are adequate. This is not the case—there is no early warning system in place to prevent thenext financial crisis and this is a crucial resource that the Bank of England requires in order to fulfil its role.2.1.1 HM Government has already stated that under the previous tripartite regulatory system, the Bank ofEngland “while having statutory responsibility for financial stability, had only limited tools to deliver it” (P4,“A new approach to financial regulation: building a stronger system”, February 2011).2.1.2 Three years on from the onset of the financial crisis and the systems and processes for the Bank ofEngland to collate the necessary information from Systemically Important Financial Institutions (SIFIs) thatcan then be used to identify the build up of risk across the whole of the financial system, are not in place. Thisis despite the technology being available to establish such a “system” (see below). Equally worrying, thereappears to be no acknowledgement amongst regulators of the requirement to put such a system in place, whichis a direct result of a lack of understanding of the means to do so.2.1.3 Indeed, up until the recent publication of HM Treasury’s proposals for the regulatory system (“A newapproach to financial regulation: judgement, focus and stability”) on the 17 February, there was no one bodytaking ownership of this issue. Now the interim Financial Policy Committee will have responsibility formonitoring systemic risk but, as it stands, does not have the ability to do so and there appears to be anassumption amongst regulators and policy makers that such a system is already in place. It is not.2.1.4 Intellect therefore believes that, for the good of the financial system, there needs to be a concertedevaluation by the Bank of England of the sort of information it needs to collate in order for it to identify risksthat are building up across the financial system. A systemic risk “early warning system”, entrenched in thelegislation required to enact the new regulatory system, can then be developed by both industry and theregulators. Such as the system is already being assessed for development by the Office of Financial Research(OFR) in the United States (a product of the recent Dodd-Frank Bill). The creation of the European SystemicRisk Board (ESRB) is also indicative of the importance that the European Central Bank (ECB) is attaching tothis issue in terms of maintaining financial stability across the Euro zone.2.1.5 European Systemic Risk Board (ESRB) and has been acknowledged by these institutions as essentialfor maintaining financial stability.2.1.6 Whilst Intellect is the trade association for the UK technology industry, this is not necessarily atechnology issue. Instead, monitoring systemic risk is about setting appropriate standards and oversight for astable financial system. What is lacking is therefore twofold:—Consideration of this issue alongside other “big ticket” regulatory reform issues such as capitaland liquidity requirements, the potential split up of banks and bankers bonuses (amongst others)by policy makers and regulators. The impact that the lack of such a system prior to the financialcrisis and the impact that another financial crisis would have on the UK economy makes this apolitical and regulatory priority.—A mandate, preferably from Government, to build a set of standards and processes that can helpidentify risk right across the financial system.Systemic risk—the current situation2.2 On a systemic level, the financial crisis exposed the weakness of the UK’s and US’s financial servicesregulatory framework and in particular the asymmetry of information between the regulators and financialservices providers. HM Treasury and regulators across the global financial system have already stated this wasa major contributing factor to the financial crisis.2.2.1 The result was that the prudential regulatory system was not equipped to manage systemic risk. Theinformation gap between the tripartite regulatory authorities and the financial institutions slowed the responseto the financial crisis. Whilst the Government was able to step in and save RBS and HBOS, albeit at a highcost, this was undertaken without full knowledge of the risks that the banks faced, and an accurate, holisticassessment of what risk their collapse would have posed to the financial system as a whole.2.2.2 In the U.S. where the regulatory system suffered from the same deficiencies, a slowed response timemeant that the authorities could only act to save one of Lehman Brothers or AIG, and the rest is history.2.2.3 The problem stems from the fact that the data that regulatory authorities currently have access to fromfinancial services providers are neither in a uniform standard (making it much harder to collect, compare and cobberPack: UPL: CWE1 [O]Processed: [03-11-2011 13: 30]Job: 012044Unit: PG01Treasury Committee: EvidenceEv w3analyse what the data means) nor is it granular enough. I.e. this data is not of a sufficient standard to allowregulators to paint an accurate picture of the realities of the positions of individual SIFIs, and in doing so, ofthe financial system.2.2.4 The complexity of the global financial services industry and the products within it have themselvesprovided something of an opacity which is directly responsible for complicating the task of viewing the wholeof the financial services system, and assessing risk therein. There is currently very little motivation for financialservices institutions to reduce this opacity as a lack of transparency is conducive to the development of complexand profitable products. In short, it is good for business. Other sectors, such as pharma, aerospace and thechemicals industry have all increased their own transparency through regulator-enforced modernisation—iestandardising the flows of data from individual companies to regulators. It is no surprise that as transparencyof a specific industry is increased, the effectiveness of that specific regulator increases as well. If industriessuch as this can modernise, there is a strong argument for an industry as economically and socially critical asthe financial services industry, to modernise as well. The financial services industry is also capable of the samemodernisation of its data flows (precisely what is required for a systemic risk “system”), despite itsprotestations—this capability is already demonstrated on a daily basis through the vast amounts of trade datathat is channelled at great speed between institutions operating in the capital markets (high frequency tradingis a notable example).2.2.5 On a UK level there is currently very little leadership on this issue and as a result the UK regulatoryauthorities (i.e. the Bank of England, and the Financial Policy Committee specifically) are in no better positionto monitor the build up of systemic risk than it was before the financial crisis. If the next banking crisis werearound the corner, the asymmetry of information between the financial service providers and regulators wouldbe of a similar level to that in 2008 and there would, once again, be a tough choice for regulators to make asthey had not been able to act sooner—i.e. to step in and bail out stricken banks, or let them fail with uncertainconsequences for the rest of the economy.Implementing an early warning system—UK is lagging behind2.3 In the United States the OFR has been established within the US Treasury Department as a result of theDodd-Frank Bill. Its remit is to improve the quality of financial data available to policymakers and facilitatemore robust and sophisticated analysis of the financial system. In effect, the OFR is permitted by law todemand data from financial companies including banks, hedge funds, private-equity firms and brokerages. Itwould be able to track information such as counterparties for credit-default swaps and would, crucially, affordregulators the sort of system-wide overview (including darker parts of the market) that will allow it identifywhen and where there is a risk to financial stability. All this, and the fact that the OFR has recently starteddefining reporting standards for the financial community puts it way ahead of the Financial Policy Committeein terms of establishing tools to head off the next financial crisis.2.3.1 On a European level the ESRB was established, again by law, in December 2010 under the auspicesof the European Central Bank and has a similar function to the OFR. Whilst it is not yet as advanced as theOFR in terms of its use of data, it is also still way ahead of the UK as it has acknowledged that data standardsthat will allow it to collate information from 75 different member organisations (including the ECB, the EUnational central banks and EU national regulatory authorities amongst others) are not sufficient to allow it toundertake its role effectively.2.3.2 That the both these institutions have acknowledged that current data standards are insufficient to affordregulators the necessary systemic risk early warning systems, should Intellect believes, be heeded by the Bankof England and acted upon now, whilst the regulatory system is being reformed.What would a systemic risk early warning system look like?2.4 In order to carry out its role of maintaining financial stability by monitoring systemic risk and steppingin to mitigate where necessary, the Bank of England will need to implement an overarching “systemic riskutility” that will collate information from individual financial institutions and present it in a way that it can beanalysed and interpreted by the FPC. It is envisaged that, ultimately, the front end of this system could representa “dashboard” that could inform and alert the Bank of England.2.4.1 Advances in computing power, data storage and analytical techniques mean that the creation of thisutility for the entire financial system is now a viable proposition. Systemic risk (macro) analytics aim toquantify risks relating to the broad-scope, long-term dynamics and dependencies of major markets and players,and are associated with significant shifts in market state. By contrast, market and credit risk (micro) analyticshave a narrower scope, make linear extrapolations from recent market trends, and assume localised shifts inaggregated market parameters.2.4.2 Such a system would require the following components:Reference Data (including standard legal entity identifiers):—A means to gather, cleanse, organize public reference data for end to end cash flow risk analysis. cobberPack: UPL: CWE1 [E]Processed: [03-11-2011 13: 30]Job: 012044Unit: PG01Ev w4Treasury Committee: Evidence“System of Systems” Approach:—Reuse of existing components in an open and extensible architecture.Collaborative Analytics:—Establish a secure, collaborative analytic tooling for risk valuations and analytics across thefinancial system.Data-driven Stress Tests and Interventions:—Support for stress-testing and targeted intervention driven by actual position and counterparty data.2.4.3 However, it is worth noting that the burden of developing this “system of systems” should not fallwholly on the Bank of England. It is the collection and use of non-standardised data within individual financialinstitutions that poses the fundamental challenge in detecting and mitigating the build up of systemic risk andwhich made it near impossible for the regulatory authorities to identify risk signposts in the lead up to therecent financial crisis and intervene before it became necessary to bail out financial institutions.2.4.4 Therefore it is envisaged that the bulk of the cost of such a system should be borne by the industry,who dedicate millions of pounds per year into developing commercially orientated low latency IT systems thatcontribute significantly to their performance in financial markets and have significant profit making capabilities.2.4.5 As a result of such a system, the entire financial industry will benefit from central provision of cleanreference data instead of the current situation with each enterprise having to cleanse and maintain its own. Thiscould save the industry millions of pounds per annum as well as reducing the chances of bank failure andincreasing market certainty.In the short term ...2.5 Measuring systemic risk will be iterative and a multi-year effort, however pragmatic steps can be takento start now. Initially better data management can help consolidate existing data and systems for better analysisand insight, and will define the minimum set of data standards and reporting requirements to allow cross-firmand cross-market analysis. Data models can be developed to analyse data gaps currently impeding systemicrisk measurement, to aggregate and link data across a large number of financial institutions and markets,identify important data that is currently inaccessible, and define consistent data “tags and identifiers” forsecurities attributes and legal entities. Alongside the models data analytics will measure different dimensions ofsystemic risk to develop automated processes for continual stress testing, standardise approaches for gatheringnormalised data from multiple institutions, and develop forensic and “what if” scenarios and simulations.Overall this will enable the development of macro prudential regulatory and systemic risk tools that can runscenarios and simulation techniques to further support the transparent monitoring of the financial system.Security ofdata2.6 What does also fall upon the Bank of England regardless of what means it uses to monitor systemic risk,is the requirement to ensure that the data it collects and houses from across the financial system, is secure tothe appropriate level.2.6.1 Given the sensitive nature of the data that is collected, the negative impact upon individual bankinginstitutions and the economy as a whole would be significant if this data were to be compromised. Consequentlythere would need to be formalised and independent oversight in place to ensure that data security standardswere constantly maintained and evaluated—in keeping with the same standards and oversight that all otherpublic sector institutions are obliged to maintain. There are currently 6 Impact Levels relating to informationheld by public bodies ranging from IL 1 (unclassified) through to IL6 (top secret). The Bank of England wouldneed to determine just how sensitive the information it holds is (and the impact if it is lost/compromised) todetermine the appropriate Impact Level. It is envisaged that the Bank of England would have to work withCESG (the information assurance arm of GCHQ) here to determine what level (and what safeguards) wereappropriate for which processes.2.6.2 That the Bank of England is taking on more responsibility in this area under the proposed reforms tothe financial system requires it to apply greater resources to information assurance.3. Are the Responsibilities of the Court of the Bank of England Clear and Appropriate?3.1 Given that the Court of the Bank of England is responsible for:—Ensuring the effective discharge of the Bank’s functions.—Ensuring the most efficient use of the Bank’s resources.—Reviewing the Bank’s strategy in relation to the Financial Stability Objective.3.1.1 ... it is therefore the Court’s duty to ensure that the FPC has the tools in place to measure the build upof systemic risk and, as outlined above, to evaluate what information it needs to receive from financial servicesinstitutions across the system, so that it can adequately discharge its responsibility to monitor systemic risk. cobberPack: UPL: CWE1 [O]Processed: [03-11-2011 13: 30]Job: 012044Unit: PG01Treasury Committee: EvidenceEv w53.1.2 Intellect would urge the Court to play close attention to the work being undertaken by the OFR andthe ESRB to this end to ensure that the FPC has the appropriate tools and to work with the ICT industry asearly as possible to ascertain what the Bank’s requirements will be, what is possible and how to undertakethis task.Achieving Value for Money3.2 As part of the IT systems required for the new regulatory system, Intellect would also urge the Court ofthe Bank of England and other relevant bodies responsible for ensuring that value for money is achieved inthe procurement and implementation of IT systems for the new regulatory environment, to involve industry asearly as possible to seek advice and work with those suppliers that will ultimately be rolling out the requiredsystems anyway. On a wider level, there is a strong argument for the proposed regulatory authorities to involveindustry as early as possible in its deliberations for new initiatives, so that costly regulatory proposals can beevaluated, with duplication of effort and unnecessary expenditure (for government, regulators and financialservice providers) kept to a minimum.3.2.1 The case of the FSA’s approach to implementing the Single Customer View (SCV) as part of theFinancial Services Compensation is an example of how not to do this. It was estimated in an independentfeasibility study for the FSA, that the cost of adapting bank’s IT systems to accommodate this new regulationwas in the region of £1bn. A commercially-focused SCV has been the goal of established banks for some timenow, in order to manage individual customers’ “touch-points” and allowing a more personalised service. Thereis a strong argument that if the FSA had sought to involve the technology industry at an early stage to determinehow to adapt existing SCV capability, rather than re-inventing the wheel, the result would have been quickerand easier to implement; and significantly less expensive. At a time when there are two state owned banks thatneed to deliver value for money, it makes little sense for regulation to “re-invent the wheel” when there aresystems already in place within banks that can be adapted to achieve the same result.3.2.2 Intellect already partners with the Office of Government Commerce, HM Treasury and the CabinetOffice amongst other government departments to ensure that such situations are avoided and it would seemlogical that the Court consider this path as well.March 2011Written evidence submitted by AvivaPolicy Functions Within the Bank of England1. It is important that the relevant supervisory authority has responsibility for engaging in and determiningthe policy relating to the prudential supervision of regulated firms. This means that the Prudential RegulationAuthority (PRA), not other parts of the Bank of England (the Bank), should be responsible for micro-prudentialpolicy and engage with stakeholders as appropriate.2. The PRA, not other parts of the Bank, must represent UK insurers’ interests with the European Insuranceand Occupational Pensions Authority to ensure a credible approach to EU negotiations is maintained, providethe industry with clarity and enable constructive engagement in the process of developing future regulation.Membership and Accountability of the Financial Policy Committee3. The membership of the Financial Policy Committee (FPC) must have identifiable expertise to cover allfinancial sectors. The selection process for appointing members to the Committee should be transparent. Thisprocess should aim to ensure that expertise covers all financial sectors and is not overly focused on banking.We would strongly welcome the appointment of members with experience of insurance and members withexperience of asset management.4. The expertise of the membership of the FPC should be subject to scrutiny by the Treasury Committee.5. We note that the FPC will be accountable to the Court of the Bank of England. We welcome HMTreasury’s proposal for this to be supplemented by Parliamentary scrutiny. We believe that the TSC shouldreview the performance of the FPC and take evidence from the Chair.6. The FPC should consult and publish a cost-benefit analysis for each of the tools it has aimed to addresssystemic risk. This information is very important to ensure that the FPC is both effective and efficient in itsactions and able to make informed regulatory decisions.7. Overall, the additional powers that are proposed for the FPC (and the Bank) mean that it should be subjectto greater levels of transparency and accountability than apply to the FSA.Membership and Accountability of the Board of the Prudential Regulatory Authority8. The membership of the Board of the Prudential Regulatory Authority (PRA) must have identifiableexpertise to cover all financial sectors that it supervises. The selection process for appointing members to the cobberPack: UPL: CWE1 [E]Processed: [03-11-2011 13: 30]Job: 012044Unit: PG01Ev w6Treasury Committee: EvidenceBoard should be transparent. This process should aim to ensure that expertise covers all financial sectorssupervised by the PRA and is not overly focused on banking. We would strongly welcome the appointment ofmembers with experience of insurance and members with experience of asset management.9. The expertise of the membership of the Board of the PRA should be subject to scrutiny by the TreasuryCommittee.10. We note that the PRA will be accountable to its Board, HM Treasury and the National Audit Office. Wewelcome HM Treasury’s proposal for these forms of accountability to be supplemented by Parliamentaryscrutiny. We believe that the TSC should review the PRA’s performance and take evidence from its ChiefExecutive and Chair.11. The discipline of attending these sessions would focus the minds of the Board and executive managementteam on their roles, objectives and challenges to delivery. This would provide a form of accountability andoversight of the PRA’s governance.31 March 2011Written evidence submitted by the British Bankers’ AssociationIntroduction1. The British Bankers’ Association welcomes the opportunity to give evidence to the inquiry by the TreasuryCommittee into the accountability of the Bank of England. We represent 220 banks from 60 countries and have40 associate firms within membership.2. The Treasury Committee has separately inquired into the reform of the regulatory structure. Under this,the Financial Services Authority (FSA) will cease to exist in its current form and will be replaced by two newbodies: the Prudential Regulation Authority (PRA), a new subsidiary of the Bank of England (Bank) focusingon the regulation of banks, deposit-takers, insurers and certain investment firms; and the Financial ConductAuthority (FCA), which will be responsible for the regulation of conduct of business for all firms and wholesalemarkets, as well as the prudential supervision of investment firms not supervised by the PRA. A new FinancialPolicy Committee (FPC) will also be made responsible for macro-prudential policy and will sit alongside theMonetary Policy Committee (MPC) within the Bank of England.3. In response to the earlier inquiry, we explained that the BBA is supportive of the broad structure of thenew UK regulatory framework, including the emphasis to be placed on financial stability and the intention toestablish a firmer linkage between the micro-supervision of individual firms and the additional macro-prudentialregulation intended to enhance systemic stability. But we also highlighted certain areas requiring...

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