2015年-数据局_德勤：全球银行入账模式打造成功的体制改革_19页_3mb

Summary: Global Bank Booking Models and Structural Reform

Core Content

This document explores the evolving landscape of global banking booking models and how regulatory and supervisory reforms are reshaping them. It highlights the increasing emphasis on transparency, simplicity, and alignment with prudential standards, which are driving changes in how banking groups structure their operations and manage risks.

Main Viewpoints

• Regulatory Impact: Post-financial crisis reforms have shifted the focus from market risk optimisation to reducing complexity and ensuring legal entity rationalisation. Supervisors are now more systematically scrutinising booking practices, including remote booking and back-to-back transactions.
• Structural Changes: Banking groups are moving towards simpler, more localised structures, with a greater emphasis on regionalisation and fragmentation. This is driven by the need to meet resolvability and ring-fencing requirements.
• Stakeholder Alignment: Banking groups must balance the needs of customers, investors, and supervisors. Customers want flexibility and access, investors seek efficient and transparent operations, and supervisors require robust risk management and clear documentation.
• Strategic Opportunity: Booking model changes can be a strategic tool to improve efficiency, reduce costs, and align with broader regulatory and business goals. A group-wide approach is recommended to address these changes effectively.

Key Information

Regulatory Drivers

• Resolvability: Resolution planning is increasingly influencing booking models, with supervisors identifying "impediments to resolvability" and pushing for structural and operational changes.
• Ring-fencing:
  • UK: By 2019, large deposit-takers must be ring-fenced, separating retail and investment banking.
  • EU: Proposals for similar ring-fencing may be introduced, affecting both EU and non-EU banks with significant EU operations.
  • Switzerland: G-SIBs are restructuring to separate domestic retail operations from overseas investment banking.
  • US: Foreign banks with US subsidiaries above $50 billion in assets must establish an Intermediate Holding Company (IHC), promoting local governance and transparency.

Booking Model Components

• A booking model includes:
  • Product mix and client base
  • Risk management and operating structure
  • Legal entities and financial arrangements
  • Governance and control frameworks
• It dictates how and where trades are booked, and how risks are managed.

Supervisory Expectations

• Supervisors expect clear understanding of:
  • What products are transacted
  • Which legal entities are involved
  • How risk flows through the group
  • The rationale behind booking decisions
• They are increasingly concerned with:
  • Alignment of risk location and management
  • Capital and liquidity adequacy
  • Robust documentation and transparency
  • Independent capability of local operations

Business Needs

• Banking groups need to ensure:
  • Efficiency in operations
  • Cost control
  • Transparency and simplicity in their booking practices
• These needs are often intertwined with regulatory compliance, making booking model reform a strategic priority.

Strategic Considerations

• Review and Documentation: A comprehensive review of current booking practices is essential. This involves:
  • Gathering data from multiple sources
  • Identifying gaps in documentation and understanding
  • Assessing the rationale behind current practices
• Future-State Planning: After identifying issues, banking groups should:
  • Explore concrete options for change
  • Perform technical and regulatory feasibility assessments
  • Consider tax and operational implications

Conclusion

• The future of global banking booking models is closely tied to regulatory and supervisory reforms.
• A strategic, group-wide approach is necessary to address these changes effectively.
• By aligning booking models with regulatory expectations, banking groups can enhance efficiency, reduce risk, and improve stakeholder confidence.

Appendix Highlights

• Prudential Framework: Includes capital requirements, stress testing, and other risk management elements.
• Derivatives Regulation: Influences how trades are structured and managed.
• Market Access: Affects the ability of banking groups to operate in different jurisdictions.
• Regulatory Considerations: Include transfer pricing, revenue sharing, and the use of non-regulated entities in booking practices.

Contacts

• The document is intended for global banking groups, particularly those with significant trading operations.
• It is relevant to boards and senior management, especially CFOs and CROs.