The UK Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) have today published a review of the changes introduced last year which were put in place to reduce the barriers to entry for new financial institutions. The purpose of the measures was to enable increased competition in the banking industry, to the benefit of customers. The changes focussed on two key areas: reforms to and a simplification of the authorisation process for new banks; and a major shift in the prudential regulation, such as capital requirements, for new entrants.
The two areas of focus were:
- A new ‘mobilisation’ option where authorisation is granted when a firm has met key essential elements but with a restriction on their activities due to some areas still requiring completion.
- Capital and liquidity requirements for new entrants are now lower than before, but are set against a requirement for a firm to show the regulators that it has a clear recovery and resolution plan in place in the event of it getting into difficulty in the future.
In the twelve months following the changes, the PRA authorised five new banks and there has been a substantial increase in the number of firms discussing the possibility of becoming a bank with the regulators. In the twelve months to 31 March 2014 the regulators held pre-application meetings with over 25 potential applicants. These firms have a range of different business models from retail and wholesale banking to FCA-regulated Payment Services firms who are looking to enter the banking market and offer deposits and lending to their current client base (including small SMEs) and others who are proposing to offer a mixture of SME or mortgage lending funded by retail and SME deposits.
The minimum amount of initial capital required by a new entrant bank is £1m compared to £5m under the previous regime. The on-ramp strategies have been helpful for applicant firms that may previously have faced challenges in raising capital or investing in expensive IT systems without the certainty of being authorised.
The PRA intends to publish statistics regarding banking authorisation annually.
In the Australian context, we know from recent client work that potential new entrants face a stiff climb to gain access to the local market. Consideration should be given to given to emulate the UK approach, because we need greater competitive tension in Australian banking.
