The PRA has published a consultation on the final element of Basel 3.1 implementation in the UK: the internal model approach to market risks. Key proposals include: Extending the monitoring period for the profit and...
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UK Finance launches access to banking scheme
UK Finance has announced its expanded ‘Breaking the Cycle’ pilot, aimed at improving access to banking services for people who many face barriers to opening a bank account. The initiative is delivered in...
PRA finalises some low impact amendments and consults on more
The PRA has finalised a set of low impact amendments to its rules on Fees, Skills, Knowledge and Expertise and SS3/18, and is consulting on more, which will: update the Groups part of the Rulebook; make consequential...
FCA bans CMC’s misleading MVF commission adverts
The FCA has banned misleading adverts published by Conclusive Finance Ltd – a claims management company which also trades as PCP Refunds – relating to motor finance commission redress. Specifically, the FCA...
FCA tightens eligibility requirements in final motor finance compensation scheme
The FCA has published a policy statement setting out of the terms of its motor finance redress scheme. The consultation received over 1,000 responses, with conflicting feedback as to the FCA’s proposals. The core...
PRA finalises changes to resolution planning requirements
The BoE and PRA have finalised changes to firms’ resolution reporting and disclosure requirements. The key changes include: Increasing the threshold for firms in scope of the Resolution Assessment Framework...
BoE consults on new approach for CCPs
The BoE is consulting on a new statement of policy on how it will use its permissions and requirements powers to create a discretionary “mobilisation” stage when onboarding new central counterparties. The...
PRA clarifies that Credit Unions may invest in service organisations
The PRA has published its policy statement amending the credit union investment rules to provide that credit unions may invest in credit union service organisations (CUSOs) subject to certain conditions. The changes...
PRA invites views on improving regulatory reporting for banks
The PRA has issued a discussion paper on regulatory reporting for banks under its Future Banking Data programme. The programme aims to reduce costs for firms in line with the regulator’s competitiveness and growth...
PRA writes to CFOs on resolvability
The PRA has written to CFOs of major UK banks on their preparations for the third Resolvability Assessment Framework assessment which will include a detailed assessment of firms’ ability to achieve the Continuity...
PRA publishes final Basel 3.1 policy documents
The PRA has published its final instruments, supervisory statements, statements of policy, and templates to reflect Basel 3.1. The measures reflect the revised UK implementation date for the Basel 3.1 requirements of 1...
PRA publishes 2026 supervisory plans
The PRA has published its supervisory priorities for 2026. Its main plans focus on streamlining supervision, so that periodic supervisory meetings and other activities will move to a two year cycle – an initiative...
Committee private markets report concludes too many “unknown unknowns”
The Financial Services Regulation Committee has published a report following its inquiry into the growth of private markets in the UK. Private markets, mainly in the form of private equity funds and private credit funds...
Court considers scope of s26 FSMA
The Court of Appeal was asked to consider whether failure of a law firm to have advised that arrangements constituted collective investment schemes made Claimants who essentially operated and promoted the schemes liable...
Regulators update Regulatory Initiatives Grid
The latest edition of the Regulatory Initiatives Grid updates on timelines for 124 live initiatives across the 9 organisations covered by the grid. The press release heralding the publication highlights the themes of:...
PRA updates policy on managing climate-related risks
The PRA has published its final policy on enhancing banks’ and insurers’ approaches to managing climate risks. The consultation had planned – among other things – to strengthen governance...
FCA updates on access to cash regime review
The FCA has given an update to the Treasury Committee on its access to cash regime. The FCA’s rules on access to cash came into force in September 2024, and require designated banks and building societies to...
FCA launches open finance tech sprints
In order to support the delivery of open finance, the FCA has launched 2 new TechSprints and announced a new partnership with Raidiam. The partnership with Raidiam follows the launch of its Smart Data Accelerator in...
FCA updates on open banking progress
The FCA has published a research note it commissioned to collect views on open banking and finance in the UK. It wanted a good understanding of the current state of open banking to help to inform future development. The...
UK Finance announces live pilot project on tokenised sterling deposits
UK Finance has announced a live pilot project to deliver the first UK transactions of tokenised sterling deposits. The pilot will run until mid-2026 and consider three use cases: Person-to-person payments via online...
Treasury consults on Commercial Credit Data Sharing scheme
HM Treasury has published a consultation and call for evidence on enhancing the UK’s Commercial Credit Data Sharing (CCDS) scheme. which facilitates the sharing of credit informaiton on SMEs between lenders and...
Treasury confirms next budget date
HM Treasury has confirmed that the next budget will be released on Wednesday 26 November 2025, and will address an economy that the Chancellor feels is ‘not working well enough for working people’. Rachel...
BoE speaks on “multi-money” system
Sarah Breeden – Deputy Governor of Financial Stability at the BoE – has delivered a speech on innovation in money and payments at the Bank of England and Warwick Business School Innovation in Money and...
Challenger banks continue to lead CMA satisfaction survey rankings
The Competition and Markets Authority (CMA) has published its latest set of banking satisfaction results, which show that the challenger banks continue to rank higher than their traditional counterparts. Monzo is ranked...
FCA creates wholesale banks webpage
The FCA has created a new page on its website to bring together the results of its various workstreams involving wholesale banks. The page contains the output from its reviews on: conflicts of interest in share buybacks...
Financial Services Regulators Complaints Commissioner publishes annual report
The Financial Services Regulators Complaints Commissioner has published its annual report for 2024/25. Key findings included: 954 complaints and enquiries were closed; 325 complaint elements were investigated, of which...
PRA makes depositor protection changes
The PRA has published its policy statement on its implementation of the Bank Resolution (Recapitalisation) Act 2025, which requires it to amend the Depositor Protection Part of its Handbook. The changes: introduce the...
FCA updates on firm support
The FCA has updated its website to explain how it can support both UK and international firms, and how it is working with the Government to help firms and individuals to do business in the UK.
Mansion House speech supports Leeds Reforms
The Chancellor’s Mansion House speech, delivered in the evening of 15 July, highlighted many of the Leeds reforms, and set out the Chancellor’s key priorities. She highlighted: for capital raising, recent changes to the...
PRA publishes measures to help mid-size credit institutions
ThePRA is planning some adjustments to its Basel 3.1 implementation to better help mid-size banks and building societies while maintaining market stability. The changes affect the Fundamental Review of the Trading Book...
Government publishes plans to apply FSMA style regulation to the CRR
HM Treasury is progressing its work to apply the FSMA model to the assimilated laws for banks, building societies and investment firms. It has published a policy paper confirming its approach to implementing Basel 3.1...
Government announces “Leeds reforms”
After the Edinburgh reforms, we now have the Leeds reforms! The Government has announced an ambitious package of measures to attract inward investment into the UK and financial services businesses. Rachel Reeves announced the UK’s first Financial Services Growth and Competitiveness sector plan. The plans include:
giving consumers support to invest;
create good skilled jobs;
encouraging banks to offer investment opportunities to people with cash in low-interest accounts;
encouraging the industry to highlight to consumers the opportunity to invest when they can – the Government says that, based on current trends, if consumers move �2,000 from low interest accounts into stocks and shares, they could be over �9,000 better off in 20 years’ time;
the BoE will allow more lending at over 4.5 times a buyer’s income and simplified FCA Rules, if adopted, will make remortgaging easier. The changes will also allow the Nationwide to make its “Helping Hands” scheme available to lower income borrowers – now the thresholds are �30,000 for solo and �50,000 for joint applicants (�5,000 lower than previously);
there will be a new government-backed Mortgage Guarantee Scheme to ensure high loan-to-value mortgages are available in times of economic uncertainty;
FOS will need to align its decisions more closely with FCA rules;
the SMCR will be radically streamlined;
the FCA is to review how the Consumer Duty affects and applies to wholesale firms;
the MREL threshold will be raised to �25-49bn;
the Basel 3.1 rules will come in from January 2027;
reform of the ring-fencing regime;
a major FPC review of bank capital requirements;
providing bespoke support to fintechs;
greater financial capacity for the British Business Bank; and
progressing the Berne Financial Services Agreement, so that it is fully implemented by the end of the year.
See our separate posts on some of these initiatives!
Committee launches inquiry into growth of private markets
The Financial Services Regulation Committee has launched an inquiry into the growth of private markets in the UK, following regulatory capital and liquidity reforms introduced after the global financial crisis in 2008...
BoE launches DLT innovation challenge
The BoE has launched a distributed ledger technology (DLT) innovation challenge in collaboration with the Bank for International Settlements Innovation Hub London Centre. The challenge aims to engage with the private...
HM Treasury makes wholesale cash oversight orders
HM Treasury has confirmed which firms operating in the wholesale cash distribution system have been recognised under Part 5A of the Banking Act, which gives it the power to specify persons involved in wholesale cash...
FCA apologises to FundingSecure customers
The FCA has responded to consumers who lost money as a result of P2P lender FundingSecure Limited’s administration. Complainants had asked the FCA to compensate them for the losses they suffered, on the basis that the FCA had not properly authorised and supervised the firm.
The FCA says that the losses did not result from its actions, but it does accept it should have:
done more to understand that the firm’s business model changed and it started to offer property development loans; and
ensured an approved person was responsible for client money.
Post-authorisation, the FCA believes its oversight was reasonable and proportionate.
So it has not upheld any complaints, but it will make payments of between �50 – �250 to complainants because it took it so long to respond.
The new Scottish security regime – we’ve updated our guide
Under the Moveable Transactions (Scotland) Act 2023, major changes to how to create effective fixed security over certain types of assets located in Scotland (including Scottish shares and bank accounts) took effect on 1 April 2025.
Two new forms of fixed security over assets � a statutory pledge and an assignation of claims � introduce more streamlined ways of taking fixed security over certain assets, reduce the administrative burden, and allow fixed security to be created over current and future assets (including by certain individuals and corporate entities which can’t grant floating charges).
For current and potential deals, lenders/security agents should consider taking security over Scottish assets under the new regime (and for existing deals, whether there is scope under existing debt documents (for example, undertakings or further assurance provisions) to take advantage of the new regime to have a more robust Scottish security package).
We’ve updated our guide to the Act. Please contact [email protected] and/or [email protected] if you have any questions.
LSB finds financial services chatbots do not meet customer needs
The LSB has published new research which found significant inconsistencies with customers’ experiences with financial services provider ‘webchat’ services, including considerably differences in functions supported by AI...
TheCityUK calls for easier defence sector financing
TheCityUK and ADS have published a report calling for the government to reduce perceived risks in the defence industry to make it easier for UK security businesses to access finance and investment. The report includes...
PRA updates on SME and infrastructure lending adjustments
The PRA has updated its previous policy statement on SME and infrastructure lending adjustments, to align with its proposed updates to Pillar 2A methodologies and guidance as part of its overall review.
PRA consults on Pillar 2A review
The PRA is consulting on Phase 1 of its Pillar 2A capital review. The paper focuses on how the PRA will address the consequential impacts of the near-final PRA rules implementing Basel 3.1, and also includes proposals to improve information, guidance and transparency for firms. Other proposed changes look to� improve the proportionality of regulation.
The changes address:
credit risk
operational risk
pension obligation risk and
market and counterparty credit risk.
Consultation closes on 5 September.
PRA updates approach to international bank supervision
The PRA has updated its SS5/21 and published a policy statement on business within branches of international banks that operate in the UK, and on what it expects from those entities in terms of booking models and liquidity reporting.
It says it has updated its approach to keep its open approach to international banking, while maintaining safety of the UK system. It has increased the thresholds around FSCS-covered deposits by 30% but has also introduced a new indicative threshold of �300m of total retail and small business instant access deposits above which it would expect the bank to have a UK subsidiary rather than a branch. The PRA has made this, and a few other, changes, partly in response to lessons learnt from the Silicon Valley Bank collapse.
PRA consults on removal of SS20/15 for building societies
The PRA is consulting on removing SS20/15, which sets out its supervisory expectations in relation to the treasury and lending activities of building societies, following a review that has led it to conclude that: the...
Treasury outlines new customer protections against debanking
HM Treasury has outlined new rules which will require banks and other payment service providers (PSPs) to give customers 90 days’ notice before closing an account or terminating a payment service. Relevant firms...
FCA publishes guidance for international wholesale firms looking to enter UK
The FCA has published a webpage targeted at international wholesale firms looking to undertake activities in the UK. The guidance sets out: Minimum standards for authorisation, including details on the threshold...
PRA sets out final rules on step-in risk assessments
The PRA has published a policy statement setting out its updated requirements on the identification and management of step-in risk The new rules – based on Basel Committee on Banking Supervision guidelines –...
PRA publishes Fees and Levies rates proposals for 2025/26
The PRA today published its CP 8/25, setting out its proposals for fees and levies for the current year.
The Annual Funding Requirement, to cover the PRA’s ongoing regulatory activities, is �328.7m, down �2.6m from last year; similarly, the Total Funding Requirement, which comprises the AFR and other levies, is down by �10.5m from last year, to �342.5m.
Points of interest from the consultation include an outline of how the PRA will be funding work on Future Banking Data, which will build on the Banking Data Review and the ongoing collaboration with the FCA around Transforming Data Collection.
Deletion of underused or duplicative templates will be consulted on, and a firm-facing portal will be developed, facilitating interaction with the PRA, presumably along the same lines as the recently-launched MyFCA.
PRA publishes Business Plan
The PRA’s 2025/6 Business Plan focuses on: significant work already completed on competitiveness and growth – such as the capital requirements to support SME and infrastructure lending, making the Solvency...
Employment legislation update March 2025
Employment Rights Bill – this had its second reading in the House of Lords on 27 March. The Committee stage is due to start on 29 April. The Bill contains numerous provisions, which include: Employees will have the...
CMA consults on SME banking undertakings
The Competition & Markets Authority (CMA) has launched a review of the SME Banking (Behavioural) Undertakings given in 2002 by nine clearing banks following a market investigation by the then Competition Commission...
FCA publishes latest Handbook Notice
The FCA has published its latest Handbook Notice, which confirms the following updates: Amendments to FEES including to: Add the 2025/26 management expenses levy limit figures; Increase registration fees for small...
BoE launches 2025 Bank Capital Stress Test
The BoE has launched its 2025 Bank Capital Stress Test, aimed at the seven largest and most systemic UK banks and building societies. The test replaces the Annual Cyclical Scenario, and involves a hypothetical stress...
LSB finds ethnic minority-led businesses less likely to have full loan applications approved
The Lending Standards Board has published new research which found that UK ethnic minority-led businesses (EMBs) are three times less likely (19%) than White British-led businesses (58%) to have their lending product...
Treasury launches call for evidence on small business access to finance
HM Treasury has launched an open call for evidence on small businesses’ access to debt finance in the UK. The call for evidence covers all aspects of the lending market, demand for finance, the application and...
FCA says sustainability rules do not prevent defence investment
The FCA has published a statement explaining that its sustainability rules do not prevent investment in or finance for defence companies. It explains that the aims of its sustainable finance rules are to ensure...
CMA reaches settlement with banks over gilt information
The CMA has reached settlement with 5 banks in relation to exchanges of information by traders on buying and selling gilts on specific dates. Individual traders shared competitively sensitive information in one-to-one...
PRA makes changes to simplify capital communications
The PRA has finalised the rule changes needed to allow it to streamline firm-specific capital communications. The changes do not change the capital requirements on firms but will simplify the content and process of the...
Get our guide to the new Scottish security regime
Under the Moveable Transactions (Scotland) Act 2023, major changes to how to create effective fixed security over certain types of moveable assets located in Scotland (including Scots law contracts) will take effect on...
Treasury publishes more responses on strategy recommendations
HM Treasury has published responses from the Prudential Regulation Committee and Financial Policy Committee to its letters setting out recommendations. the Prudential Regulation Committee response notes what the PRA has...
FCA publishes climate change “adaptation” report
The FCA has published a report requested by DEFRA, looking at the major issues that affect climate change adaptation in the financial services industry. Its research and its discussions with firms highlighted 3 major...
UK Finance calls for urgent review of BoE MREL proposals
UK Finance has responded to the BoE consultation on its approach to setting a minimum requirement for own funds and eligible liabilities (MREL). It says the Bank must radically change its approach to both the assets and...
PRA outlines supervision priorities for international banks and deposit takers in 2025
The PRA has published Dear CEO letters to international banks and designated investment firms, and UK deposit takers, setting out its supervision priorities for 2025. The need for robust governance, risk management and...
PRA delays Basel 3.1 implementation
The PRA, in consultation with HM Treasury, has decided to postpone the implementation of the Basel 3.1 framework by one year to 1 January 2027. The delay will allow more time for clarity on how the framework will be...
A new Scottish security regime
Major changes to how to grant and take effective fixed security over certain types of Scottish assets (including rental income, debt claims, insurance policies, material contracts, and other moveable assets (like stock...
Ring fencing changes regulations made
Changes to the ring-fencing regime will take effect in February and will implement changes to improve how the regime works. The changes both resolve unintended consequences of the current law, provide greater...
BoE sets out approach to stress testing the banking system
The BoE has set out its approach to stress testing the UK banking system from 2025 onwards, which will sit within its broader framework for assessing financial stability and the soundness of individual banks. The BoE...
BoE publishes system-wide stress test results
The BoE launched its first system-wide exploratory exercise of how a range of firms behave in stressed market conditions mid-2023, it has now published a final report on how the UK financial system would respond to a...
Government acts on “smarter” ring fencing regime
Following the 2023 consultation by the previous government on implementing the recommendations of the Panel led by Sir Keith Skeoch to review the workings of the ring-fencing regime for large banks that took effect in...
FCA updates AI webpages
FCA has published a new webpage introducing its ‘AI Input Zone’ a component of its AI Lab. The input zone is designed to be a means by which FCA can canvass a wide range of market participants views so as to...
PRA feeds back on CRR changes
The PRA has published feedback to its consultation on changes to certain parts of its rulebook in respect of: Disclosure and reporting in respect of various CRR requirements; changes to the Policyholder Protection Part...
Treasury publishes SME reviews as part of Budget
As part of the 2024 Budget, HM Treasury has published post-implementation reviews of the Small and Medium Sized Business (Finance Platform) Regulations 2015. These Regulations introduced a Bank Referral Scheme to...
HMT publishes Banking Liaison Panel Terms of Reference
HMT has published the Banking Liaison Panel Terms of Reference, which include reference to: The Panel’s remit, including its broad purpose and the specific functions set out under section 10(2) of the Banking Act...
HMT adds draft recapitalisation chapter to Banking Act: special resolution regime code
HMT has added a new chapter to the Banking Act 2009: special resolution regime code of practice. The new chapter provides draft details of the recapitalisation payment mechanism introduced in the Bank Resolution...
FCA updates regulatory initiatives grid
The FCA has published an interim update on its Regulatory Initiatives Grid. It had postponed the scheduled 8th edition because of the election and says that the replanning required as a result means that there...
BoE consults on amending MREL approach
The BoE is consulting on restating, where appropriate and with modifications, of UK Capital Requirements Regulation total loss-absorbing capacity (TLAC) provisions to the minimum requirement for own funds and eligible...
Waiver? What Waiver?
In the recent case of Little & Another v Olympian Homes Ltd, guarantors successfully applied to set aside statutory demands in relation to non-payment under their guarantees by relying on an argument of a waiver by...
PRA consults on changes to resolution assessment reporting
The PRA is proposing to carry out, together with the BoE, the third assessment of firms’ resolvability in 2026-27. It is consulting on a proposal to require relevant firms to submit their next reports to the PRA...
FCA and BoE publish digital securities sandbox policy statement
Following a joint consultation on creating a Digital Securities Sandbox (DSS), the FCA and BoE have published a policy statement setting out their approach to safely adopting new technologies in the operation of...
LSB updates business lending code to provide stronger SME protections on personal guarantees
The LSB has updated its Standards of Lending Practice for business customers to strengthen provisions for SMEs using personal guarantees. The standards provide the only lending protections available to many SMEs, given...
PRA publishes near-final policy statement on remainder of Basel 3.1 standards implementation
After publishing a near-final policy statement on various chapters in its consultation on the implementation of the Basel 3.1 standards late in 2023, PRA has published a second near-final policy statement in response to...
Tribunal backs FCA refusal of authorisation application on fit and proper grounds
The Upper Tribunal made its decision on the reference to it in respect of the FCA’s decision that the only proposed financial adviser of a firm did not meet the ‘fit and proper’ test, such that the...
BoE publishes second resolvability assessment of major UK banks
The BoE has published its second assessment of the resolvability of the eight major UK banks, finding that the banks have made significant progress in preparation for resolution, and have addressed issues outstanding...
BoE and PRA consult on updates to international banking supervision
The BoE and PRA have launched a consultation on proposed updates to international banking branch and subsidiary supervision to reflect changes since introducing the PRA’s SS5/21. The proposed changes include:...
Government responds on Special Resolution Regime enhancements
The Government has published its response following its consultation on enhancing the Special Resolution Regime and the Bank Resolution (Recapitalisation) Bill has now started its Parliamentary Passage. Respondents were...
King’s Speech 2024 outlines pensions and banking resolution measures
Among the list of legislative proposals referred to in the King’s Speech are bills designed to strengthen pension investment and enhance the UK’s banking resolution regime. The Pension Schemes Bill aims to...
FCA updates SUP notification form
The FCA has created a new form on its website for use by firms and insolvency practitioners making a Principle 11 notification. The purpose of the form is to get the information the FCA will need to assess how to deal...
Basel Committee publishes revised Core Principles for effective banking supervision
The Basel Committee on Banking Supervision (BCBS) has finalised its revised Core Principles for effective banking supervision, which were endorsed by banking supervisors and central bankers representing more than 90...
Government responds further on progress of Edinburgh reforms
The Government has published a second formal response to its December 2023 report on the progress of the Edinburgh reforms. This response is more detailed than the Government’s initial response and includes an...
PRA writes to CROs on private equity related activities
Following a PRA review of private equity financing businesses, it has now written to bank Chief Risk Officers noting the key conclusions. It specifically notes a recent trend that increases exposure to various non...
BoE speaks on role of private equity
Nathanael Benjamin of the BoE has spoken on the role of the private equity market, focusing on its key role in financing companies but looking also about safe and sustainable growth. Key points from his speech included:...
Government sets out third phase of Smarter Regulatory Framework
Following its Smarter Regulatory Framework (SRF) delivery plan, Treasury has published a follow-up paper which sets out the progress made so far and the government’s approach to the next phase of the SRF programme...
PRA publishes solvent exit planning statement
PRA has published Policy Statement PS5/24 – Solvent exit planning for non-systemic banks and building societies providing feedback to consultation paper (CP) 10/23 – Solvent exit planning for non-systemic banks...
LSB publishes lending standards consultation responses
The Lending Standards Board (LSB) has published its response to the views received on its consultation on a review of the Standards of Lending Practice (the Standards) for business customers. The review itself was...
BoE responds on PRC remit
BoE Governor Andrew Bailey has written to the Chancellor, updating last year’s response to the letter setting out the Chancellor’s recommendations to the Prudential Regulation Committee (PRC). The letter...
TheCityUK shows strength of UK financial services sector
TheCityUK’s annual report on the UK’s position as an international financial centre says that exports relative to imports of financial and related professional services shows how competitive UK industry is...
PRA writes to international banks on 2024 priorities
In a ‘Dear CEO’ letter, PRA has updated international banks and designated investment firms on its 2024 priorities. As with the other letters published today, the general themes will complement firm-specific...
PRA writes to deposit takers on 2024 priorities
David Bailey and Laura Wicks of PRA have written to UK deposit takers about supervisory priorities for 2024. The Dear CEO letter stresses that this sets out the regulator’s thematic priorities, and complements its...
Treasury consults on enhancements to the Special Resolution Regime
HM Treasury has issued a consultation on proposals for enhancing the Special Resolution Regime (SRR). Specifically, the consultation seeks views on plans to introduce a new mechanism to facilitate the use of certain...
Government commissions Transition Finance Market Review
The Government has now commissioned the market-led review into growing transition finance in the UK, originally announced in its 2023 Green Finance Strategy to help higher emitting companies and activities to...
Basel Committee consults on targeted adjustments to standard on IRRBB
The Basel Committee has published a consultation on targeted adjustments to its 2016 standard on interest rate risk in the banking book (IRRBB). Under the IRRBB standard, banks are required to calculate measures of...
PRA and FCA confirm remuneration changes for small firms
PRA and FCA have published feedback on their consultations on enhancing proportionality in respect of the remuneration rules in respect of dual-regulated and small firms. While the regulators needed to feed back...
FCA updates on LIBOR transition powers
On 1 January 2018 the EU Benchmark Regulation (BMR) took full effect. Following the UK’s withdrawal from the EU and the end of the transition period, the BMR has been brought into UK law (UK BMR). Under the UK BMR, FCA...
PRA consults on step-in risk assessments
PRA is consulting on proposed changes to rules and policy that will require CRR firms and consolidation entities that are not classified as small domestic deposit takers to regularly assess their step-in risk –...


