About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

Costs of Living Wills Requirements Likely to be Considerable But Are Hard to Estimate, Says Kinetic Partners’ Shrimpton

Subscribe to our newsletter

The UK Financial Services Authority (FSA) has just released a new consultation paper on its proposals for recovery and resolution planning requirements, which estimates that the direct costs of implementation will be between £4 million and £35 million for “high impact” firms and the ongoing compliance costs to the industry will be between £150 million and £400 million. Andrew Shrimpton, member at financial advisory firm Kinetic Partners, explains to Reference Data Review that the true costs of the changes are likely to be considerable, but are hard to determine fully at this point in time.

“Firms will be faced with a considerable expense in preparing the plans and structures necessary to meet the FSA’s requirements, however, it is difficult to estimate at this stage exactly what the costs will be,” says Shrimpton.

On this note, he indicates that the resolution plan requirements are much harder to quantify than recovery plan requirements. “Recovery plans can be implemented fairly quickly, and become part of management’s ongoing contingency planning, without extensive additional cost to the firm. The resolution plan requirements, however, are completely new, and experience of other new regulations previously implemented suggests that the costs stated could be underestimates,” he explains.

Firms won’t have long to find out the initial implementation costs, given that the FSA is planning to publish the final rules in the first quarter of next year. At that point certain provisions will come into effect that will mean firms will be required to submit the first draft of their recovery and resolution plans in June 2012. Firms will therefore have six months to get the necessary data infrastructure in place to be able to pull together the required data on demand.

“Firms will have to go through many iterations and likely seek expensive external advice to ensure they have met all the requirements,” adds Shrimpton.

Back in November 2009, Fed board governor Daniel Tarullo indicated that in order to meet living wills requirements firms will need sufficiently robust data management systems in place to track data quality and provide audit trails for regulators. He therefore noted that a “very significant upgrade of management information systems (MIS) may be the only way for the firm to satisfy living will requirements”.

Subscribe to our newsletter

Related content

WEBINAR

Recorded Webinar: Navigating a Complex World: Best Data Practices in Sanctions Screening

As rising geopolitical uncertainty prompts an intensification in the complexity and volume of global economic and financial sanctions, banks and financial institutions are faced with a daunting set of new compliance challenges. The risk of inadvertently engaging with sanctioned securities has never been higher and the penalties for doing so are harsh. Traditional sanctions screening...

BLOG

11 Providers Shaping the Capital Markets Data Governance Landscape

The vast volumes of data that capital markets participants are ingesting as a matter of necessity have placed new demands on their data estates. At a time of market volatility, increased regulatory scrutiny and growing requirements for real-time insights, keeping control of how their data is ingested, distributed and utilised has become a growing challenge....

EVENT

AI in Data Management Summit New York City

Following the success of the 15th Data Management Summit NYC, A-Team Group are excited to announce our new event: AI in Data Management Summit NYC!

GUIDE

Regulatory Data Handbook 2025 – Thirteenth Edition

Welcome to the thirteenth edition of A-Team Group’s Regulatory Data Handbook, a unique and practical guide to capital markets regulation, regulatory change, and the data and data management requirements of compliance across Europe, the UK, US and Asia-Pacific. This year’s edition lands at a moment of accelerating regulatory divergence and intensifying data focused supervision. Inside,...