On April 1, 2021, ISDA and the Association for Financial Markets in Europe submitted a joint response to HM Treasury (HMT) on its consultation on implementing the Basel III standards.

The UK Financial Services Bill allows HMT to revoke provisions from the Capital Requirements Regulation (CRR) so the Prudential Regulatory Authority (PRA) can introduce updated prudential rules for credit institutions and PRA-designated investment firms equivalent to the EU’s CRR2.

Chapter two of the consultation paper is a statement of how HMT intends to exercise its revocation power, and chapter three seeks respondents’ views on HMT’s approach to applying the standardized approach (SA) reporting requirements under the Fundamental Review of the Trading Book (FRTB).

The industry appreciates the objective of this consultation for FRTB SA reporting is to leverage the existing regulations, now entered into force in the EU. However, there are areas that we believe require consideration, particularly on how the UK can align with the Basel Committee on Banking Supervision’s international standards. Furthermore, the industry is concerned with the supervisory authorizations that might be necessary ahead of the start of FRTB SA reporting in the first quarter of 2022.