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IMF Country Report No. 22/57
UNITED KINGDOM
FINANCIAL SECTOR ASSESSMENT PROGRAM FINANCIAL SYSTEM STABILITY ASSESSMENT
February 2022
This paper on United Kingdom was prepared by a staff team of the International Monetary Fund as background documentation for the periodic consultation with the member country. It is based on the information available at the time the FSAP Assessment was completed in November 2021. This paper was discussed by the IMF Executive Board on February 16, 2021.
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Press Release
UNITED KINGDOM
FINANCIAL SYSTEM STABILITY ASSESSMENT
February 2, 2022
KEY ISSUES
Context: The U.K. financial sector is globally systemic, open, and complex. It has weathered the COVID-19 pandemic fittingly, thanks to the post-GFC reforms, a proactive macroprudential stance, and an effective multipronged response to maintain financial stability. Brexit uncertainties are being handled appropriately as the U.K. and EU authorities and the financial industry collaborate to prevent undesirable financial stability outcomes. The endpoint of the pandemic remains unclear, as does the actual impact on the financial system once support measures wane. At this juncture, therefore, financial stability conditions in the United Kingdom are being shaped by three key considerations: (i) the evolving U.K.-EU relationship on financial services; (ii) securing a sustainable and robust post-pandemic economic recovery; and (iii) successfully managing ongoing structural transitions.
Findings: The U.K. financial system is benefiting from a robust financial stability framework. The FSAP team has assessed capital and liquidity levels at core banks and insurers as strong—even under some severely adverse scenarios, including the re-emergence of the pandemic, and a tighter monetary policy stance. The financial stability institutional framework rests upon effective interagency collaboration. The globally critical market infrastructures remain in good form, and the authorities have shown leadership in the global LIBOR transition. With these positives, the FSAP recognizes five areas that could bear upon financial stability as the pandemic subsides and global financial conditions change: (i) the strength of banks and insurers could give way to potential risks posed by their counterparties; (ii) a buoyant housing market may encourage overborrowing; (iii) financial interconnectedness may add new channels of market interactions and contagion; (iv) surfacing of liquidity mismatches in the internationally active NBFIs; and (v) the post-Brexit operating models of international banks and financial firms. Collectively or singularly, these pose a challenge for the financial stability authorities.
Policies: Fully recognizing the strengths, the FSAP has proposed four directions going forward: (i) bolstering management of systemic risks; (ii) continued strengthening of regulation and supervision; (iii) minimizing risks of transitions and future crises; and (iv) securing institutional safeguards for financial stability and market integrity. A few of the FSAP recommendations necessitate active cooperation from cross-border central banks, financial stability authorities, and regulators.
The FSAP team was led by Udaibir Das (Mission Chief). It comprised of Juan Solé (Deputy Mission Chief), Atilla Arda, Kelly Eckhold, Tamas Gaidosch, Pierpaolo Grippa, Vikram Haksar, Jan Moeller, Paola Morales, Jin Podpiera, Luc Riedweg, and Peter Windsor (all MCM); Ruo Chen (EUR); Jonathan Pampolina (LEG); and Sigridur Benediktsdottir, Timo Broszeit, Thomas Curry, Greg Feldberg, and Stathis Tompaidis (experts). The FSAP team received valuable supplemental inputs from Hans Weenink and Ender Emre (both LEG). In addition, Marika Santoro (RES) and Federico Grinberg, Romain Bouis, Priscilla Toffano, Hou Wang, Matyas Zoltan, Ken Zhi Gan, and Pavel Lukyantsau (all MCM) provided targeted analytical help. Dan Cheng and Lamia Khandker provided research and administrative support, respectively.
The mission met with Chancellor Sunak, Governor Bailey, and CEO Rathi, as well as their respective staffs at Her Majesty’s Treasury (HMT), the Bank of England (BOE), the Prudential Regulation Authority (PRA), and the Financial Conduct Authority (FCA). It also met staff at the Competition and Markets Authority (CMA), the Financial Services Compensation Scheme (FSCS), and The Pensions Regulator (TPR), and representatives of the U.K. financial industry.
FSAPs assess the stability of the financial system as a whole and not that of individual institutions. They are intended to help countries identify key sources of systemic risk in the financial sector and implement policies to enhance its resilience to shocks and contagion. Certain categories of risk affecting financial institutions, such as operational or legal risk, or risk related to fraud, are not covered in FSAPs.
The United Kingdom is deemed by the IMF to have a systemically important financial sector according to SM/10/235 (9/16/2010), and the stability assessment under this FSAP is part of bilateral surveillance under Article IV of the IMF’s Articles of Agreement
Approved By
May Khamis and Laura Papi
Prepared By
Monetary and Capital Markets Department
This report is based on the assessment work under the Financial Sector Assessment Program (FSAP) conducted virtually in June and November 2021. The findings were discussed and concluded, with the authorities in November 2021 (the close of the FSAP) and in December 2021 (the close of the Article-IV Consultation).
Contents
Glossary
EXECUTIVE SUMMARY
FINANCIAL STABILITY CONTEXT
A. Pandemic Shock and Macrofinancial Conditions
B. United Kingdom in Global Finance
ISSUES IN SYSTEMIC RISK AND RESILIENCE
A. Brexit and Financial Stability
B. Macrofinancial Linkages
C. Banking Sector Solvency and Liquidity
D. Insurance Sector Solvency and Liquidity
E. Market-Based Finance
F. Central Counterparties
G. Asset Managers
H. Systemic Liquidity and Core Markets
I. Real Estate Markets
J. Climate-Related Vulnerabilities
ISSUES IN SYSTEMIC RISK MITIGATION, OVERSIGHT, AND SUPERVISION
A. Macroprudential Framework
B. Microprudential Framework
CROSSCUTTING CHALLENGES TO FINANCIAL STABILITY
A. LIBOR Transition
B. Open Banking and Crypto Assets
C. Cybersecurity Threats
D. Combating Financial Crimes and Safeguarding Financial Integrity
PREPARING FOR FUTURE CRISES
A. Resolution Framework
B. Internationally Active Mixed Financial Groups
C. Agency Independence and Resources
AUTHORITIES’ VIEWS
BOXES
1. Structural Features of the Financial System
2. Select Financial Stability Data Gaps
FIGURES
1. Macrofinancial Indicators
2. Macrofinancial Linkages
3. United Kingdom and the Core Global Financial System
4. Systemic Stress Scenarios
5. Nonfinancial Corporates
6. Nonfinancial Corporates Under Stress Scenarios
7. Households Balance Sheets
8. Bank Stress-Tests At-A-Glance: Scenarios and Results
9. Bank Solvency Stress Test Results
10. Solvency Stress Test Results
11. Macrofinancial Feedback Effects
12. Insurance Sector—Solvency and Profitability
13. Insurance Solvency Stress Test
14. Insurance Liquidity Risk Analysis
15. Credit Cycles
16. IM and VM Margin Calls
17. Money Market Funds
18. Fixed Income and Equity Open-End Funds
19. Alternative Investment Funds
20. Systemic Liquidity Stresses and the BOE’s Response
21. Housing Price Developments and Household Debt Indicators
22. Methodological Approaches for Climate Risk Analysis
23. The Logic of the ‘Climate Minsky Moment’
24. Insurance Climate Risk Analysis
25. Indicators of the Importance of LIBOR and Transition Progress
26. Supervisory Population of Entities with AML/CFT Obligations
27. AMF/CFT: Comparison of Mutual Evaluation Report Ratings
TABLES
1. Key Recommendations
2. Selected Economic Indicators, 2018–25
3. Financial Soundness Indicators, 2015–2020
4 Core Global Financial Network, and Degree of Interconnectedness, 2020
5. High-Priority Exit Risks and Other Selected Exit Risks
6. Proportional Liquidation Asset Profile for MMFs Under a Weekly Redemption Shock
7. Proportional Liquidation Maturity Profile for MMFs Under a Weekly Redemption Shock
8. FPC’s Annual Assessment of Risks Banking and Selected Inputs
APPENDICES
I. Banking Sector Stress Test Matrix
II. Insurance Stress Testing Matrix
III. FSAP Risk Assessment Matrix
IV. Implementation Status of 2016 Key Recommendations
Glossary
| ACS | Annual Cyclical Scenario |
| AFS/FVO | Available for Sale/Fair Value Option |
| AIF | Alternative Investment Funds |
| AIFMD | Alternative Investment Fund Managers Directive |
| AML/CFT | Anti-Money Laundering/Combating the Financing of Terrorism |
| API | Application Programming Interface |
| AT1 | Additional Tier 1 |
| BIS | Bank for International Settlements |
| BMA | Bayesian Model Averaging |
| BOE | Bank of England |
| CAR | Capital Adequacy Ratio |
| CCB | Capital Conservation Buffer |
| CCP | Central Counterparty |
| CCyB | Counter-Cyclical Capital Buffer |
| CEO | Chief Executive Officer |
| CET1 | Common Equity Tier 1 |
| CIB | Corporate and Investment Banking |
| CJRS | Coronavirus Job Retention Scheme |
| COREP | Common Reporting Framework |
| CRE | Commercial Real Estate |
| CS01 | Risk of Spread Over the Benchmark Rate Moving By 1 Basis Point. |
| CSD | Central Security Depository |
| CVA | Credit Value Adjustment |
| DV01 | Risk of The Risk-Free/Benchmark Rate Moving 1 Basis Point |
| ECL | Expected Credit Loss |
| EEA | European Economic Area |
| ESMA | European Securities and Markets Authority |
| ETF | Exchange Traded Fund |
| EU | European Union |
| FCA | Financial Conduct Authority |
| FATF | Financial Action Task Force |
| FINREP | Financial Reporting |
| FMIs | Financial Market Infrastructures |
| FPC | Financial Policy Committee |
| FRF | Future Regulatory Framework |
| FSMA | Financial Services and Markets Act 2020 |
| FSSA | Financial System Stability Assessment |
| FSAP | Financial Sector Assessment Program |
| FSB | Financial Stability Board |
| FSCS | Financial Services Compensation Scheme |
| FSR | Financial Stability Report |
| FVA | Fair Value Accounting |
| FX | Foreign Exchange |
| GAAP | Generally Accepted Accounting Principles |
| GDP | Gross Domestic Product |
| GFC | Global Financial Crisis |
| GFM | Global Macro Financial Model |
| G-SIB | Global Systemically Important Bank |
| GTAP-E | Global Computational General Equilibrium Model |
| HMT | Her Majesty’s Treasury |
| IAIS | International Association of Insurance Supervisors |
| ICP | Insurance Core Principle |
| IFRS | International Financial Reporting Standards |
| IM | Initial Maturity |
| IMF | International Monetary Fund |
| IOSCO | International Organization of Securities Commissions |
| IRS | Interest Rate Swaps |
| JMLIT | Joint Money Laundering Intelligence Taskforce |
| KA | Key Attributes of Effective Resolution Regimes for Financial Institutions |
| LCR | Liquidity Coverage Ratio |
| LGD | Loss Given Default |
| LIBOR | London Interbank Offered Rate |
| LME | London Metal Exchange |
| LTV | Loan to Value |
| MA | Matching Adjustment |
| ML/TF | Money Laundering/Terrorism Financing |
| MMF | Money Market Fund |
| MoU | Memorandum of Understanding |
| MPC | Monetary Policy Committee |
| MTM | Mark-to-Market |
| NBFI | Non-Bank Financial Institutions |
| NECC | National Economic Crime Centre |
| NFC | Nonfinancial Corporates |
| NGFS | Network of Greening the Financial Sector |
| NPL | Non-Performing Loan |
| O-SII | Other Systemically Important Institutions |
| OB | Open Banking |
| OBR | Office for Budget Responsibility |
| OEF | Open-ended Fund |
| OFI | Other Financial Intermediary |
| OIF | Other Investment Fund |
| ONS | Office for National Statistics |
| OPBAS | Office of Professional Body Anti-Money Laundering Supervision |
| OTC | Over the Counter |
| PBS | Professional Body Supervisor |
| PD | Probability of Default |
| PiT | Point-In-Time |
| PNFC | Private Non-Financial Corporation |
| PRA | Prudential Regulation Authority |
| PRC | Prudential Regulation Committee |
| PSC | People with Significant Control |
| PVA | Present Value |
| RAF | Resolvability Assessment Framework |
| RAM | Risk Assessment Matrix |
| RBB | Risks Beyond Banking |
| RFRs | Risk Free Rates |
| RLF | Resolution Liquidity Framework |
| RRP | Recovery and Resolution Plan/Planning |
| RWA | Risk Weighted Assets |
| SCR | Solvency Capital Requirement |
| SEC | U.S. Securities and Exchange Commission |
| SMEs | Small and Medium-Sized Enterprises |
| SOA | Systemic Oversight Assessment |
| SRA | Systemic Risk Analysis |
| SRB | Systemic Risk Buffer |
| STeM | Stress Test Matrix |
| SVAR | Structural Vector Auto Regression |
| TCA | Trade and Cooperation Agreement |
| TMTP | Transitional on Technical Provisions |
| TPR | The Pensions Regulator |
| TR | Trade Repository |
| UCITS | Undertakings for the Collective Investment in Transferable Securities |
| TTC | Through-The-Cycle |
| U.K. | United Kingdom |
| WTO | World Trade Organization |
| WEO | World Economic Outlook |
| y-o-y | Year-on-Year |