What does regulatory change mean for your business?
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1 whatwouldyouliketogrow.com.au What does regulatory change mean for your business? PwC Regulatory Change Benchmarking Survey July What would you like to grow?
2 PwC Regulatory Change Benchmarking Survey The volume and complexity of regulatory change, both in Australia and around the world, is placing a significant burden on our banks. And the lack of clarity about requirements and the ambitious implementation dates are adding to those challenges. Banks who responded to our survey believe that the current regulatory reform projects are either very important or important to their strategic objectives. However, the newness of many of these reforms means it s too early to identify the true impact on customers and profitability, or to understand the full cost of implementation. With this in mind, banks are not just focusing on achieving compliance but are directing senior management s attention towards considering the business implications. Where banks were once reactive to regulatory change, there is a growing awareness that this round of regulatory reform has the capacity to act as a catalyst for much broader change particularly in the areas of funding, liquidity and financial markets and that the more agile movers could gain an advantage. The ability to influence international regulatory reforms is a key concern Having emerged from the GFC relatively unscathed, Australian banks are frustrated by the limited influence they are able to exert in global regulatory change negotiations. While they are continuing to work through industry groups and are lobbying the Australian government and regulators, they are also exploring new avenues. This includes lobbying other governments and regulators through global connections established by their international branches and affiliates. However, the banks are concerned that the global reform process is being dominated by national agendas and that this will perpetuate the lack of transparency and consistency which existed before the GFC. In the case of major international reforms such as Basel III, banks accept that it is not realistic for Australia to opt out or receive concessionary treatment. However, they see a real need for international alignment. Not only would differences in implementation affect comparisons, but they would flow across borders, as foreign bank branches are subject to the capital rules of their home regulator regardless of where they are operating. Different rules could lead to an uneven playing field and create the opportunity for exploitation. In addition, new regulations such as the USA s Dodd-Frank and FATCA reforms have international compliance implications on a scale previously unseen. How important is managing regulatory reform overall to your strategic objectives and how ready is your organisation to meet the requirements? Bank Bank Bank Bank 4 Bank 5 Bank 6 Bank 7 Bank 8 = less important/not ready = important/ready = very important/very ready Importance Readiness What does regulatory change mean for your business?
3 The political landscape at home is another area of concern Responding to the many reforms being proposed here in Australia is causing its own issues. While the banks believe they have a voice in the reform process, the sheer volume of reforms being considered makes it difficult to provide timely and measured responses. A large amount of senior management time is being spent influencing the Government s reform agenda through written submissions, attending parliamentary inquiries and lobbying. The banks consider that they have had mixed success in influencing the political process. They find this frustrating, particularly when they believe that the outcomes of the new reforms may be of mixed benefit to their customers. PwC comment In PwC s Banking Banana Skins Survey an annual survey of global CEOs about the risks their businesses face Australian CEOs and senior management cited political interference and too much regulation as the top risks facing their institutions in the post GFC world. Their concern was that overreactions to the GFC would see banks being loaded with burdensome and inflexible rules, damaging not only to banks but to the broader economy. These appear to be continuing concerns. How important is each regulatory reform to your strategic objectives and how ready is your organisation to meet the requirements of the reform? Importance to strategic objectives important Important Less important Anti-money laundering NCCP Privacy legislation G PPSR Financial claims scheme ready Ready Not ready Readiness to meet requirements Liquidity Capital Dodd-Frank FATCA What are the key findings? Volume of reforms means significant complexity for implementation and compliance Inconsistencies in the way countries implement global reforms threatens to undermine the reforms effectiveness It is frustrating that concerns about negative customer impacts arising from local reforms have been caught up in the political process Implementation is hazardous when the rules aren t clear or lead times are short Diverting resources away from customerfocused projects may have unintended consequences Total compliance costs are expected to be high; identified project costs are already running in the hundreds of millions of dollars and many projects are yet to be costed The potential for reforms to materially impact current operating models is only just being recognised What does regulatory change mean for your business?
4 Ambitious timetables and the lack of detail are creating implementation risks The regulatory reform setting process such as NCCP, PPSR, G Financial Markets Reforms and FATCA has seen regulators announce their broad intent together with short implementation timetables but little detail about the requirements. This lack of clarity, given the short implementation dates, was one of the most commonly cited implementation risks in the survey. In some cases, to achieve compliance by the required date, banks have had to start the implementation process, intending to make adjustments down the line as detailed requirements become available. This approach makes it difficult to secure appropriately skilled resources on a timely basis and to fit into key systems pipelines. Reforms are often bolted onto existing processes, frequently using manual work-arounds, with less than optimal outcomes in process efficiencies, costs and customer impacts. Focusing on project structure To drive greater efficiencies and mitigate unintended customer impacts, senior management is paying closer attention to the way projects are structured. As a result, there has been a shift away from compliance-focused centralised projects towards more business-centred projects with business management sponsorship. The opportunity cost of reform may never be known Banks raised concerns that with so many changes occurring simultaneously, they are being forced to divert a significant proportion of their investment spend into implementing the reforms. This takes resources away from customer-focused strategies and may ultimately have the opposite effect to that intended by the reform. One survey respondent said I don t enjoy going to the executives with compliance projects. This reflects the level of frustration banks are experiencing at not being able to get on with business, and a lack of alignment between regulatory initiatives and better business outcomes. Most banks are finding it difficult to identify all the related project costs, either because of the project structure (the project is being run as business as usual ) or because it is too early to assess the full costs when the detailed implementation requirements remain sketchy. Where costs can be identified, they run to the tens if not hundreds of millions of dollars, indicating that the cost across the system is substantial. Those costs will ultimately be borne by customers through higher prices, and by shareholders through lower returns on equity. Current operating models are under threat While no one has underestimated the far-reaching nature of the current round of reforms, many respondents revealed that their organisations, and indeed the broader business community, are only now beginning to understand the potential implications. Survey respondents from the larger institutions highlighted the potential for Financial Markets Reforms to fundamentally change their financial markets businesses, as well as possibly producing lower profits and return on equity. Boards and senior management are responding to these concerns by becoming more actively involved in the projects. They are appointing more senior resources to assess the implications for bank-wide strategies, and to manage implementation to achieve more desirable outcomes. About the survey The PwC Regulatory Change Benchmarking Survey was conducted between March and May. Respondent banks were ANZ, BOQ, Bendigo Bank, CBA, Macquarie, NAB, Suncorp and Westpac. Respondents were asked to complete a questionnaire and PwC conducted several interviews with staff from each bank. The results were collated by PwC and form the basis of this report. So what are the implications? Staying on top of new developments, co-ordinating responses and keeping the board informed is critical. The centre can t do everything. Engaging with the business early in the implementation process will help ensure business and customer impacts are assessed and successfully mitigated. Co-ordination across projects is a key ingredient for success as many reforms affect the same underlying business processes and systems. Stepping up efforts to improve non-financial data quality will deliver better business and customer outcomes in the long run. 4 What does regulatory change mean for your business?
5 Our clients say... It s a full time job keeping up with all the changes let alone understanding what they mean for the business and working out how to respond FATCA is going to make AML look like a picnic It is taking the attention away from the business What does regulatory change mean for your business? 5
6 Detailed Findings Regulatory reform: managing the changes Organisations achieve compliance through their corporate values, codes of conduct and business processes. The myriad of change currently on the regulatory reform agenda is posing a significant challenge for compliance functions, which need to ensure that business units implement the new regulatory requirements and at the same time meet stakeholders expectations by maintaining compliance with ethical standards such as keeping their promises to their customers. Are new regulatory requirements leveraged/used as a platform to drive improvements within the business? 9% 8% Yes, for implementation of new systems and processes Yes, for improvements to existing systems and processes 4% No While non-compliance can have dire consequences in terms of penalties and reputation, robotic compliance can also have consequences in terms of poor business outcomes and customer experience. To address this, some banks have appointed senior managers to oversee implementation and ensure risks are appropriately identified, measured and monitored. Banks are aware of the risk of focusing too much on compliance and diverting attention away from the business which can ultimately have the opposite effect to that intended by the regulations. The regulatory change agenda is rapidly gaining board and senior executive attention as its pervasiveness into the customer experience and business strategy becomes more apparent. 6 What does regulatory change mean for your business?
7 Implementation risks Survey respondents were asked to identify their top 5 implementation risks for each regulatory reform package. There was a surprising degree of uniformity in the responses. Risks identifed by respondents Business & financial impact Regulatory setting process IT & process reengineering 4 Resourcing % of mentions Although there are significant challenges in the availability of project management resources and the re-engineering of systems and processes, it is interesting to see that even these substantial concerns are overshadowed by the business and financial impact of the reforms and the regulatory-setting process. A lack of clarity about requirements combined with ambitious implementation dates and the need to manage the sheer volume of reforms is creating major challenges and risks for project teams. Many implementation timetables don t allow sufficient time to integrate requirements into already overloaded systems and process re-engineering timeframes, resulting in bolt-ons and manual work-arounds, which may lead to inefficiencies and a higher risk of non-compliance further down the track. Unintended consequences for customers, negative impacts on profitability, and a lack of engagement from business units were the most cited risks with the current reform agenda. Securing skilled resources to ensure successful implementation is a risk recognised by many respondents, as banks compete for a small pool of resources with relevant experience. What does regulatory change mean for your business? 7
8 Basel III Capital & Liquidity Both a lack of high quality capital and insufficient liquidity have been identified as key contributors to the GFC. Post-GFC, the G leaders tasked the FSB and BCBS with developing an extensive prudential reform package addressing shortcomings in bank capital and liquidity a package now known as Basel III. While the Australian banks are better placed than many of their global counterparts to meet the more stringent Basel III rules, the package still presents challenges for achieving compliance. How significant is the impact of the Basel III requirements on your business? 6 With implementation dates set way out in the future, there are pros and cons around early adoption Number of respondents 5 4 Not No Impact 5% 5% 5% 5% Does your organisation intend to: Adopt Early, within the next years Adopt Early, outside years Adopt on implementation date Undecided All respondents agree that the Basel III reforms will have a significant impact on their business. However, they are divided about the best time to implement. Some standardised banks are more focused on achieving advanced accreditation in order to reduce the amount of additional capital required under Basel III. Capital and liquidity management are now more complex than ever. Respondents identified educating boards and executives as the most important aspect of Basel III. And they considered the most challenging aspect to be managing investor relations. Please rank the impact of the following challenges arising from the Basel III requirements in relation to your organisation Board Education Systems & Infrastructure There is concern about the lack of consistency in the way Basel III is being adopted by national regulators. Australia s banks are some of the safest in the world, yet because of differences in national approaches, on the face of it they may appear more risky than their global peers. Investor Relations Liquidity Management Capital Management Business Strategy Banks are undecided about what the overall impact of Basel III will be on business profitability as they are still working through the impact passing on costs may have on business volumes within each customer segment. Public Stakeholder Management Moderate high Importance Difficulty 8 What does regulatory change mean for your business?
9 G Financial Markets Reforms Another contributor to the GFC identified by the G leaders was the lack of transparency and supervision of OTC derivative markets, which led to systemic market risks. The FSB has been working with market regulators and central banks to develop a set of reforms to address these concerns. Proposed reforms include standardising derivative contracts, trading on exchanges or electronic trading platforms and clearing through central counterparties with strengthened capital requirements. US regulatory reforms Dodd-Frank The Dodd-Frank Wall Street Reform and Consumer Protection Act introduces new regulators and extends regulations over new markets, entities and activities. The legislation is complex and its full impact will not be known until all the studies have been conducted, reports written and regulations issued. These developments will affect Australian financial services organisations that have subsidiary or branch operations in the US or who interact with the financial markets in the US through debt raising and derivatives trading. How significant is the impact of the G Financial Markets Reforms on your business? 5 How significant is the impact of Dodd Frank legislations on your organisation? 4 Number of respondents 4 Number of respondents Not No Impact Unsure of Impact Not No Impact Unsure of Impact Much of the detail that the banks need to see before making critical decisions is yet to be released. Banks were concerned about the lack of progress in Australia and the limited understanding in the broader corporate community about the implications for pricing of risk management products. The financial markets reforms, which are perhaps the most significant on the G reform agenda, are seen as a big bank issue, with smaller banks falling into line with requirements where applicable. Executives are very engaged in exploring the strategic challenges these reforms present. Central to the banks strategies is assessing how the introduction of a clearing system will affect their business. With profitability under threat, the balance of power may shift in favour of other products such as corporate lending and advisory business. There is significant uncertainty about how the G Financial Market Reforms and US Dodd- Frank legislation will work together. This is reflected in the number of respondents who are unsure about how these reforms will affect them. Most respondents noted that the lack of clarity about the application of this legislation and its interplay with other global reforms is making it difficult to secure project resources and investment. Dodd-Frank has a shorter implementation timeframe than the G Financial Markets Reforms, so bankers are expecting to have to implement the new rules and then undertake re-work as conflicts between the two reforms are resolved further down the track. What does regulatory change mean for your business? 9
10 US regulatory reforms FATCA The US Foreign Account Tax Compliance Act of 9 (FATCA) will dramatically change the existing system of US withholding tax and has major implications for all financial services institutions with activities in the US. Global entities are expected to identify income paid to US nationals throughout their global operations and to report to the US tax authority. Non-compliance will result in significant penalties on cash flows generated in the US. The act potentially affects all financial services companies. How significant is the impact of FATCA legislations on your organisation? 4 Number of respondents Not No Impact Unsure of Impact One respondent commented The proposed reforms will cost a fortune if enacted as currently drafted. Respondents are very concerned that the proposed FATCA legislation will require major system and business process changes with no value add for customers or shareholders. Banks are frustrated by their inability to gain significant relief from this law, which is essentially an anti-tax evasion act for US citizens. Commentators believe that the legislation is not aimed at countries with transparent tax systems (such as Australia), but banks have no choice but to comply or risk substantial penalties and the ability to transact globally. What does regulatory change mean for your business?
11 National Consumer Credit Protection (NCCP) NCCP is a national act which replaces a number of state-based credit codes governing how credit providers extend credit to consumers. It contains responsible lending provisions aimed at ensuring credit providers do not provide unsuitable products to consumers. Credit providers must obtain a licence from ASIC and adopt credit assessment standards. Personal Property Security Register (PPSR) The introduction of a national PPSR has far reaching, if not well understood, implications for banks. Once the national register is implemented, a legal charge over personal property (eg a motor vehicle lease) must be recorded on the register to be legally effective. Banks must ensure that their business systems and processes meet the PPSR requirements by the implementation date. The New Zealand experience has shown that data integrity issues and knowledge gaps can lead to creditors not having legal title to a security in the event of default. How significant is the impact of the NCCP legislation on your business? Number of respondents 4 How significant is the impact of the PPSR on your business? Number of respondents Not No Impact Not No Impact Respondents are divided about the significance of the impact of NCCP on their business as a whole but most acknowledge that it is significant for those areas of the business that are affected. Some of the reforms have changed the ground-level decision-making processes for credit applications, which now require re-calibration to iron out problems (such as an unintended increase in declined applications in some businesses which in turn is affecting business volumes). One bank noted It is the biggest compliance project the bank has ever had in terms of cost due to its impact on systems and business processes. Industry wide costs are estimated to be in the range of $5m $m. PPSR is not a compliance requirement but a business one. Banks can make a conscious decision about whether or not to comply. The choice is either to spend the money to establish links to the register or to accept a lower level of security. The requirements are complex and quite technical but contained within particular areas of business and consumer lending. One of the biggest challenges for banks is educating their business customers about the impact of the register. Respondents were concerned about the timeliness of communications from the Attorney General s Department. This could be addressed by the department taking a more collaborative approach to resolving issues and setting timeframes. What does regulatory change mean for your business?
12 pwc.com.au PwC Regulatory specialists Sydney Melbourne Brisbane Chris Cooper p: () e: chris.cooper@au.pwc.com Nicole Salimbeni p: () e: nicole.salimbeni@au.pwc.com Kylie Rixon p: () e: kylie.rixon@au.pwc.com Richard Gossage p: () e: richard.gossage@au.pwc.com Sandra Birkensleigh p: (7) e: sandra.birkensleigh@au.pwc.com Tim Allman p: (7) e: tim.allman@au.pwc.com Kate Greenhill p: () e: kate.greenhill@au.pwc.com Jim Power p: () e: jim.power@au.pwc.com Perth Richard Groves p: () e: richard.groves@au.pwc.com Angela Barter p: () e: angela.barter@au.pwc.com Praveena Karunaharan p: () e: praveena.karunaharan@au.pwc.com Patrick Cloran p: () e: patrick.cloran@au.pwc.com Sam Hinchliffe p: () e: sam.hinchliffe@au.pwc.com Bruce Cuthbertson p: () 86 9 e: bruce.cuthbertson@au.pwc.com Sheron Warren p: () e: sheron.warren@au.pwc.com Hilde Marais p: () e: hilde.marais@au.pwc.com Justin Carroll p: (8) e: justin.carroll@au.pwc.com For further information or copies of this report, please contact: Mary Carboni +6 () 866 mary.carboni@au.pwc.com PwC. All rights reserved. PwC refers to PwC, a partnership formed in Australia or, as the context requires, the PwC global network or other member firms of the network, each of which is a separate and independent legal entity. Williams Lea 9575
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