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Rethink regulatory reporting: Structural reform

Structural Reform Reporting

What is structural reform reporting?

Jonathan Cobb

Director, Solutions & Digital

KPMG in the UK


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In July 2016, the Consultation Paper 25/16 was produced, setting out a proposal on the reporting requirements for ring-fenced bodies (RFBs). These reporting requirements form part of the wider structural reform initiative intended to improve the overall resilience of the United Kingdom’s largest banks.

The reporting of data will facilitate the Financial Conduct Authority's (FCA's) supervision of RFB sub-groups and monitoring their relationship with other parts of its group. The ultimate aim of this is to ensure banks are able to provide their core services, through protection from the risks associated with other parts of its banking group or the wider global financial system. 

Summary of reports

Consultation Paper 26/16 has detailed the following returns to be reports, along with their reporting level and frequency:

Return Proposed reporting Level Frequency
PRA109 / RFB001 Intragroup exposures and credit risk mitigation RFB sub-groups Quarterly
PRA110 / RFB002 Intragroup funding transactions
PRA111 / RFB003 Core intragroup balance sheet, and, profit and loss items
PRA112 / RFB004 Detailed breakdown of intragroup balance sheet, and, profit and loss items RFB sub-groups Annually
PRA113 / RFB005 Report on VAT/Bank levy payable RFB on behalf of the RFB sub-group Annually
PRA114 / RFB006 Amount of excluded activities conducted by RFB sub-group members
PRA115 / RFB007 Usage of FMIs by an RFB and RFB sub-group members
PRA116 / RFB008 Total use of each exception by the RFB Individual RFB Annually

The Prudential Regulatory Authority (PRA) has developed XBRL (eXtensible Business Reporting Language) taxonomies and proposes that firms submit structural reform data in XBRL format. 

Timeline and eligibility

The requirement for structural reform reporting comes into force on 1 January 2019, with various reporting frequencies, as outlined above.

Banks required by the Financial services and Markets Act 2000 (FSMA), as amended by the Banking Reform Act, to ring-fence their ‘core activities’, will be subject to the reporting requirements initially outlined in CP25/16.

The eligibility criteria, therefore, are those banking groups with ‘core’ deposits in excess of £25 billion and those who expect to meet this threshold by the 1 January 2019. 

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