There is fair amount of change happening in financial services
regulation in the UK with the creation of new regulators and a new legislative
framework. As Hector Sants warned in
2012, “the changes will not just be structural but involve behavioural shifts
from both supervisors and firms.”
Amongst all these changes and moves, there seems to be one emerging common factor
between the FCA and PRA and between them and the FSA: business model analysis
(BMA). It has a strong overlap with the underlying business strategy. A BMA has been described as answering six
questions:
- How does the company create
value?
- Who does the company
create value for?
- What is the source of
competence?
- How does the company competitively
position itself?
- How does the company make
money?
- What is the company
size ambitions?
“where
incumbent firms have suffered competitive pressure in particular business
lines, it is not uncommon for such firms to be tempted to increase the level of
risk they run to protect their market positions, or ‘diversify’ into other
areas in which they may not have the same level of expertise.”
This represents a healthy move away from supervision based on compliance with rules to supervision focused on the business and the underlying risks that arise from the strategy. The BMA provides then a base line that enables supervisors to understand how
trends impact on risk taking or business strategy.
Given that supervisors have been behind the application of BMA in
financial services, BMA remains to a large extent a supervisory tool. Will it remain so? Are there potential gains to financial
services businesses from undertaking a BMA, even if there is no supervisory visit
in the near future?
I would be interested on your thoughts.
I would be interested on your thoughts.