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Prudential Regulation

About the Prudential Regulation Division

The Prudential Regulation Division focuses on the issues affecting member firms as a result of potential or proposed changes to the prudential regulatory framework, whether arising globally, regionally in the EU, or at national level in the UK. The division works both proactively and reactively with regard to regulatory, legislative, and policy initiatives, and with respect to implementation by the supervisory authorities in the UK and other Member States. The division affords member firms a forum to identify, raise, and discuss prudential issues and concerns. In addition, it seeks to:

  • Work toward appropriate, measured, and globally consistent regulatory responses, which result in proportionate and practical outcomes for firms;
  • Press for quality policy development taking account of the tools of better regulation; and
  • Maintain and enhance AFME's status as a trusted interlocutor; foster a regulatory dialogue with the industry; and contribute industry expertise in order to facilitate an informed debate about regulation.

Key Issues and Initiatives

The regulatory agenda is currently driven by financial turmoil. The G-20 have mapped out a plan of action that they wish to see pursued, and the Financial Stability Board and the Basel Committee have been tasked with addressing the issues that arise in relation to prudential regulation at the global level. Europe has its own parallel programme for regulatory reform, confirmed by ECOFIN and driven by the European Commission, which is largely consistent with the global agenda. The thematic priority issues (being addressed globally, regionally, and nationally in the UK) are as follows:

  • Market risk/the trading book capital requirements;
  • Liquidity;
  • Definition of capital;
  • Securitisation;
  • Macro-prudential supervision/systemically important firms;
  • Counter-cyclical measures;
  • Leverage ratio; and
  • EU supervisory architecture.

These issues encompass, at the EU/national level, the implementation of CRD 2, the negotiation of CRD 3, the recent consultation on CRD 4, and forthcoming proposals consultations for CRD 4/5. At the global level a consultation is expected from the Basel Committee on a number of these issues, and calibration work continues in respect of the July 2009 publication.

Organisation

Priorities are set by the Prudential Regulation Board and taken forward by AFME staff with input from the Prudential Regulation Committee.

Board of Directors

Robert Charnley (Chair)Goldman Sachs
Marcelo Castro, Santander
Rob Everett, Bank of America Merrill Lynch
Mark Merson, Barclays Capital
Christian Lajoie, BNP Paribas
William Kerr, BNY Mellon
David Sharland, Citi
Steve Teather, Close Brothers
Arnoud Chupin, Crédit Agricole CIB
Marc Adam, Credit Suisse
Stephen Pache, Deutsche Bank
Robert Charnley, Goldman Sachs
Richard Blackburn, HSBC
Walter Smith, ING
Massimo Mocio, Banca Imi S.p.A
Graham Meadows, J.P.Morgan
Andrew Geczy, Lloyds Banking Group
Mike Mansfield, Morgan Stanley
Neil Jones, Nomura
Mary Pragnell, Royal Bank of Scotland
Sébastien Palle, Société Générale
Sean Ryan, UBS
Thomas Koenig, UniCredit

Prudential Regulation Committee

Martin Abbott, Bank of America Merrill Lynch
Kris Bhattacharjee, Barclays Capital
Kristelle Maouad, BNP Paribas
John Roy, BNY Mellon
Alain Lesjongard, BNY Mellon
Richard Hart-Johnson, Citi
Steve Teather, Close Brothers
Richard Carlson, Crédit Agricole CIB
Jeremy Evans, Credit Suisse
Caitriona O'Kelly, Deutsche Bank
Marco Bensi, Goldman Sachs
Mark Penney, HSBC
Ed Jenkins, HSBC
Walter Smith, ING
Joe Traynor, J.P.Morgan Chase
Rod Hardcastle, Lloyds Banking Group
Dawn Green, Morgan Stanley
Neil Jones, Nomura
Gordon, Haskins, Royal Bank of Scotland
Antonio Garcia Del Riego, Santander
Tony Venutolo, Société Générale
Gareth Bowen, UBS

Contact

Diane Hilleard, Managing Director
diane.hilleard@afme.eu
+44 (0)20 7743 9356

Anita Millar, Managing Director
anita.millar@afme.eu
+44 (0)20 7743 9358

Cristina Rabbini, Director
cristina.rabbini@afme.eu
+44 (0)20 7743 9362

Documents

16 July 2010
Joint Response by AFME and BBA to CEBS CP39

10 June 2010
Joint AFME, BBA & ISDA Response to CEBS CP36 - Guidelines on Liquidity Cost Benefit Allocation

18 May 2010
AFME Response to the FSA's DP09/5 Enhancing Financial Disclosures

7 May 2010
Joint Trade Association response to CEBS' implementation guidelines on Article 106(2)(c) and (d) of Directive 2006/48/EC (CP38)

16 April 2010
Joint Industry response to European Commission on CRD4 issued February 2010

Annex 2: Consolidated Responses to BCBS 164 and 165

16 April 2010
Joint trade associations' response to the Basel Committee on Banking Supervision Consultative Proposals to Strengthen global capital and liquidity regulations, BCBS 164 & 165 issued on 17 December 2009

9 April 2010
Joint Association letter to FSA on Tranche Protection Trades

1 April 2010
Joint Trade Association response to the FSA's Consultation Paper CP09/30 on Capital Planning Buffers

31 March 2010
Joint AFME/BBA/ISDA response to CEBS CP33: Guidelines regarding instruments referred to in article 57(a) of Directive 20006/48/EC Recase

31 March 2010
AFME response to CEBS CP34 on guidelinesfor supervisory colleges

31 March 2010
Joint AFME/BBA/ISDA response to CEBS CP32 revised guidelines on technical aspects of Stress Testing under the supervisory review process

31 March 2010
Joint AFME/BBA/ISDA response to CEBS CP31: Guidelines on the management of concentration risk under the supervisory review process

30 March 2010
Joint AFME/BBA response to HMT Implementation of Capital Requirements Directive 2. CP09/30

10 March 2010
Joint Trade Association Response to the FSA's Consultation Paper CP09/29 on Strengthening Capital Standards 3

4 February 2010
AFME Response to DP09/4: Turner Review Conference Discussion Paper 

January 2010
Industry Good Practice Guidelines on Pillar 3 Disclosure Requirements for Securitisation 

29 January 2010
AFME Response to EU Framework for Cross-Border Crisis Management 

31 December 2009
AFME Response to the Report and Recommendations of the Cross Border Bank Resolution Group 

30 November 2009
AFME-ICMA Response to CESR's Consultation on Guidance on Registration Process, Functioning of Colleges, Mediation Protocol, Information set out in Annex II, Information set for the Application of Certification and for the Assessment of CRAs' Systematic Importance 

31 October 2009
LIBA/ BBA/ ISDA Response to CEBS CP 28: Liquidity Buffers and Survival Periods 

23 September 2009
LIBA/ BBA Response to CEBS CP 27: Implementation Guidelines regarding Hybrid Capital Instruments 

10 September 2009
Joint Trade Associations' Response to CEBS CP 26: Draft implementation guidelines on the revised large exposures regime 

7 September 2009
Joint SIFMA/ LIBA/ ISDA Response to the European Commission Consultation on its Staff Working Document re CRD4 

1 September 2009
SIFMA/ LIBA/ ISDA/ FOA/ IIAC Joint G20 Briefing Paper 

28 August 2009
SIFMA/ LIBA/ ISDA Joint Response to the EC Communication on Efficiency, Safety & Soundness of Derivatives Markets 

17 August 2009
LIBA/ SIFMA Response to CESR's fact finding exercise on the use in the European Union of ratings issued by third countries' CRAs 

10 July 2009
LIBA/ BBA/ ISDA Response to CEBS CP 24: High-level principles for risk management 

18 June 2009
LIBA response to the Turner Review and Discussion Paper 09/02: A regulatory response to the global banking crisis 

18 June 2009
Annex to LIBA response to the Turner Review and Discussion Paper 09/02 

29 April 2009
Joint ESF/ LIBA/ ISDA/ EBF Response to the EU Commission on proposed amendments to the Capital Requirements Directive 

9 April 2009
Joint LIBA/ SIFMA/ ISDA Response to EC Communication and de Larosière Report 

April 2009
Joint ESF/ IPFed/ ISDA/ LIBA Response to BCBS CP 150: Proposed enhancements to the Basel II framework 

23 March 2009
SIFMA G20 Briefing Paper 

13 March 2009
Joint ISDA/ IIF/ LIBA/ IPFed Response to "Revisions to the Basel II market risk framework" (BCBS 148) and "Guidelines for computing capital for incremental risk in the trading book" (BCBS 149) 

9 March 2009
Joint SIFMA/ LIBA/ ICMA/ ISDA/ FOA/ IIAC Briefing for the London Summit 

18 December 2008
Industry Good Practice Guidelines on Pillar 3 Disclosure Requirements for Securitisation 

Events

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