On 16 January 2019, the PRA published a Dear CFO letter concerning disclosures about International Financial Reporting Standard (IFRS) 9 expected credit losses. The Dear CFO letter refers to the November 2018 report prepared by the Taskforce on Disclosures about Expected Credit Losses which contained certain recommendations that the PRA expects firms to implement in full. The Dear CFO letter also provides some additional comments that the report mentions as areas on which the Taskforce…

On 16 January 2019, the Court of Justice of the EU (ECJ) handed down a preliminary ruling regarding the interpretation of Articles 5(2) and 6(1)(a) of the second Electronic Money Directive (EMD II) in Paysera LT (Case C-389/17). By way of background, Article 5(2) of EMD II sets out the possible methods of calculating the own funds requirements for electronic money institutions – for activities referred to in Article 6(1)(a) of EMD II…

On 16 January 2019, the Single Resolution Board (SRB) published the second part of its 2018 policy on the minimum requirement for own funds and eligible liabilities (MREL) pertaining to the second wave of resolution plans – i.e. plans for the most complex banking groups. The second part introduces a series of new elements strengthening the function of MREL as a key tool to achieve resolvability. This includes: a point-of-entry approach will now apply to…

We are pleased to announce that our Financial Institutions (FI) team will hold a Brexit seminar in February 2019 in Paris. The objective of the seminar is to create awareness of the impact on the European financial institutions industry doing business in the UK after Brexit. Our Paris and London FI experts will give an overview of the recent developments regarding the negotiations on the future EU/UK relationship and what they are seeing in the market…

On 15 January 2019, the House of Commons’ Treasury Select Committee (the Committee) published written evidence submitted by the FCA as part of the Committee’s inquiry into consumer access to financial services (the Submission). The Submission outlines the FCA’s work and approach to issues of financial access for consumers, focusing on vulnerable people. Key points raised by the FCA in the Submission, regarding its engagement on consumer access issues, include: the FCA objectives are to…

On 15 January 2019, there was published on legislation.gov.uk a draft of The Financial Services Contracts (Transitional and Saving Provision) (EU Exit) Regulations 2019 together with an explanatory memorandum. The draft Regulations were first published by HM Treasury on 17 December 2018 (our blog is here) and have now been laid before Parliament. You can track the financial services Brexit EU Exit statutory instruments (as well as gain access to our Brexit resources) on…

On 15 January 2019, the European Supervisory Authorities (ESAs) published a multilateral agreement on the practical modalities for the exchange of information pursuant to article 57a(2) of the Fourth Anti-Money Laundering Directive (the Agreement). The purpose of the Agreement is to define practical modalities for the exchange of information between anti-money laundering / counter terrorist financing competent authorities and the European Central Bank (ECB), where such information is needed for the performance of tasks of…