BBA has responded to the consultation on secondary legislation under the Banking Reform Bill. Among other key issues, BBA raises the need to:
- simplify the certification process allowing large organisations and high net worth individuals to bank outside the ring fence;
- include "simple" options within the definition of permitted "simple" derivative products;
- allow the sale of structured deposits and investments by ring-fenced banks;
- broaden the exemptions to the prohibition on ring-fenced banks having exposures to financial institutions. Otherwise, business-as-usual relationships could be affected inadvertently; and
- widen the definition of trade finance that would be exempt from prohibitions on exposure, rather than limit it to the issue or confirmation of a documentary credit or guarantees.