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.

(Source: BBA Submission on the Financial Services (Banking Reform) Bill