As they reshape the financial services industry in light of the 2007-2008 financial crisis, global regulators have introduced a series of structural reform regulations to help build resilience. Global Structural Reform (GSR) is creating a new financial services ecosystem for institutions.
Accenture’s 2015 Global Structural Reform Study finds senior management working to thrive in what amounts to an all-new financial services landscape. They are investing effort and funds in their response to GSR, but their focus is on meeting regulatory demands. While that represents a good starting point, our study finds institutions might be missing out when it comes to meeting the strategic implications of reform and using reform as an opportunity to reposition the organization for sustainable growth
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Accenture 2015 Global Structural Reform Study: Unlocking the Potential of Global Structural Reform
1. Accenture 2015 Global Structural Reform Study
Unlocking the Potential of
Global Structural Reform
2. 2
The financial crisis of 2007-2008
highlighted the dangers of a financial
system that was improperly aligned
with the goals of systemic risk
management. Since the crisis, global
regulators have sought to re-shape
institutions to be more resilient through
a series of structural reform regulations.
Today, Global Structural Reform (GSR)
is presenting an even more complex
ecosystem for financial institutions
and, as such, constitutes a key
agenda point for senior management
driving the future strategy of their
post-crisis institutions.
3. 3
Accenture’s 2015 Global
Structural Reform Study –
based on a survey of 131
banking, insurance and capital
markets institutions across
regions – confirms that, while
institutions are investing in
their response to GSR, their
plans still appear focused on
meeting regulatory demands
alone, rather than accounting
for the more strategic
implications of structural
reform. Our study concluded:
GSR is re-writing the
financial services landscape
Publication of regulations related to
structural reform continues at a relentless
pace, with rules often developed at a
jurisdictional level without clear convergence.
In our view, it seems inevitable that the
financial services landscape will be re-
written given the cumulative impact of GSR,
especially for internationally active banks,
meaning that reliance on traditional ways of
working will no longer be viable. As a result,
institutions will be faced with hard choices
about their post-crisis business model.
Investment is clear, but strategy less so
The sheer volume of GSR regulations and
the complexity of changes they demand is
driving significant investment in talent and
technology as institutions organize their
responses. Our experience suggests a need to
validate whether strategic planning will fully
account for the strategic implications of GSR,
going beyond mere compliance and delivering
long-term value for the institution.
Unlock the potential of GSR
GSR regulations are adding further
complexity to a landscape already beset with
macroeconomic and industry disruptions.
Institutions cannot continue to solve for
point regulations without considering
other competing or complementary forces.
There is no one solution for responding to
this challenge; however, our experience
suggests three principles to help extract
greater value from the investment made:
1. Organize a long-term response
Institutions need to think end-to-end
across regulations, businesses and
geographies, and be holistic in assessing
and communicating impacts across the
operating model to make smart investments
and avoid multiple, competing projects.
2. Unlock potential in a new
ecosystem
Remaining competitive and viable in the
long term will require institutions to identify
and capture the potential for innovation
and improved financial performance
provided by the new ecosystem.
3. Demonstrate value to key
stakeholders
The value of GSR can only be realized if
planning is effectively adopted throughout
the business. As firms move past initial
compliance, further tuning of the new
operating model will be needed to help
retain engagement and support from
internal and external stakeholders.
Time for bold, strategic thinking
GSR is much more than another set of
regulatory requirements. To help their
institutions remain competitive and viable
for the long term, senior management
should approach structural reform with
the same bold, strategic thinking as they
are using for other industry challenges.
5. 5
GSR is Re-writing the Financial
Services Landscape
Rule-making in recent years has been prolific,
as regulators in individual jurisdictions have
sought to re-shape financial institutions to
add greater resilience to their operations. As
a result, rules have often been developed at a
jurisdictional level without clear convergence.
This persistent wave of GSR regulations
does not appear to be abating, and, with its
cumulative impact, reliance on traditional ways
of working — and on the infrastructure to
support such ways — will no longer be viable.
This, we expect, should leave institutions
facing some hard choices about their post-
crisis business model. Previous industry
commentary from Accenture, for example,
has indicated that capital allocation across
different business lines will be more heavily
scrutinized with a particular focus on
cross-entity flows.1
Seventy-one percent of
the 2015 Global Structural Reform Study
respondents agree that smaller institutions
may fall out of the market as they fail to
keep pace with these new market drivers. The
pressure will also be felt by larger institutions.
Accenture’s recent Banking 2020 report
highlighted the possibility that full-service
banks may collectively face losses of as much
as 35 percent of their market share by 2020
if they fail to adjust to industry disruptors.2
Institutions are starting to tailor their responses,
with three trends beginning to define how
the industry could be affected by GSR.
Geography
Developing tailored propositions by
geographic market to help drive efficiency
in the use of scarce capital. Deutsche
Bank AG3
recently announced its plans to
capture more market share in the United
States and the Royal Bank of Canada
also announcing plans to expand its US
Wealth presence through the recent
acquisition of City National Corporation.4
Products
Developing a more targeted set of offerings
that allocate capital to those business
lines able to generate appropriate returns
on equity, with other products potentially
discontinued. Barclays PLC’s recent Group
Strategy update highlighted similar themes,
for example, the stated aim of re-allocating
capital towards growth businesses.5
Client mix
Targeting more profitable client segments and
exiting relationships requiring higher costs to
serve. Last year according to news articles, Bank
of America Corporation parted ways with
a large number of hedge fund clients in an
effort to reduce costs.6
Figure 1. Projects in place to address regulatory requirements
Does your organization currently have a project in place to address the regulatory
requirements listed below? (Select all that apply)
Comprehensive Capital Analysis and Review (CCAR)
Risk planning
Implement standards, process and procedures
to avoid conflicts of interest
Implement new technology units
Ensure compliance of information
and restrict/unrestrict advice
Submit implementation plan
Implement operational process and margining, for
all bilateral over-the-counter (OTC) derivatives
Liquidity Coverage Ratio
Capital planning
Enhance client protections
Formation of Intermediate Holding Company (IHC)
Implement new risk management standards
Implement new governance model
Legal entity restructuring
Implement product governance standards
to ensure Treating Customers Fairly (TCF)
Living will/safeguard client assets
Report derivative trades
Implement conduct risk domestic/local rules
Implement a process to clear via a Central
Counterpart Clearing House (CCP)
Sequestration
63%
50%
47%
42%
40%
40%
39%
39%
37%
34%
34%
34%
32%
31%
29%
28%
28%
26%
25%
23%
Source: Accenture 2015 Global Structural Reform Study
6. 6
Figure 2. Forecasted technology and non-technology spend
What is your organization’s anticipated technology and non-technology spend (in USD)
for FY14, in order to address the global regulatory change requirement?
Source: Accenture 2015 Global Structural Reform Study
16% 13%
16%
18%
16%
10%
27%
20%
4%
20%
17%
23%
>$500m
$250m - $500m
$100m - $250m
$10m - $100m
$1m - $10m
$0m - $1m
Technology
Spend
Non-Technology
Spend
Investment is Clear, but Strategy Less So
The sheer volume of GSR regulations and
the complexity of changes they demand is
driving significant investment as institutions
organize their responses. Over half of financial
institutions surveyed as part of the Accenture
2015 Global Structural Reform Study are
forecasting investment of over $100 million
for technology, and over $100 million in
non-technology-related spend (Figure 2).
Such investment seems warranted when
one considers that fewer than one-quarter
of survey respondents are today compliant
with key GSR regulations such as Dodd-
Frank Section 165 or Basel III (Figure 3).
This investment is prompted, in part, by a
forecasted increase in headcount by surveyed
institutions, either as contingent staff to
deliver required change activity or as new,
permanent staff that will run a much-
changed business (Figure 4).
7. 7
Note: Due to rounding, total may not equal 100 percent
Source: Accenture 2015 Global Structural Reform Study
Figure 3. Levels of compliance across key regulatory requirements
At what stage is your company currently in with regards to becoming compliant with these regulations? (Select one for each)
Reviewed the regulation 10% 22% 31% 14% 24%
24%
24%
24% 24%
24%
22%
22%
22%
21%
21%
11%
7%
7%
7%
7%
7%
8%
8%
8%
18%
18%
16%
16%
16%
35%
34%
37%
31% 25%
11%
29%
29%
15%
15%
15%
24%5% 24% 22% 26%
26%
6%
6% 20% 28% 25% 21%
23%
23%
22%
17%30%
30%
34%
34%
28%
28%
18%11% 15% 30% 26%
26%
4% 19% 23% 32% 21%
18%26%6% 30% 21%
20%9% 20% 29% 24%Assessed the impact on business
Projects rolled out
Identified projects
Identified projects
Reviewed the regulation
Assessed the impact on business
Projects rolled out
Reviewed the regulation
Identified projects
Assessed the impact on business
Projects rolled out
Reviewed the regulation
Projects rolled out
Identified projects
Assessed the impact on business
Ring Fencing/
Liikanen
Markets in Financial
Instruments Directive (MiFID)
II/Markets in Financial
Instruments Regulation
(MiFIR)
Alternative Investment
Fund Managers Directive
(AIFMD)
Undertakings for the
Collective Investment in
Transferable Securities
(UCITS) IV
19%
17%
17%
17%17%
17%
48%
29%
30%26%Reviewed the regulation
Identified projects
Projects rolled out
Assessed the impact on business
Dodd-Frank
Section 165/6
Not yet stated Planning Implementing Compliant
Assurance/validating project
functionality (QA process)
21%
19%2%
4%
4%
14%
14%
8. 8
Note: Due to rounding, total may not equal 100 percent
Source: Accenture 2015 Global Structural Reform Study
This reported investment is significant and
raises the stakes for senior management to
help provide responses that are appropriate
and focused. Our experience suggests
there is a need to further validate whether
plans would fully account for the strategic
implications of GSR.
Delivering long-term value for the financial
institution will require a shift beyond a
point-regulation approach to one that
considers other competing regulations or
broader forces in the market place. In our
view, GSR regulations are adding further
complexity to a landscape already beset
with macroeconomic disruptions. Pressure
on margins, which have halved from pre-
crisis levels for European investment banks;7
customers expecting resources to be
“fingertip-ready”;8
and industry disruptions
from the rise of digital technology and
new entrants present a volatile landscape.
Making this landscape harder to navigate
with ongoing GSR regulations creates a
conundrum that institutions need to solve to
be viable in the long term, and to facilitate
creating value from investments made.
Figure 4. Forecasted spend on full-time employees
How many full-time employees (FTEs) will your organization dedicate to business (non-technology and technology)
change for FY14, in order to address the global regulatory change requirements?
20%
15%
10%
4%
18%
25%
8%
25%
17%
11%
22%
3%
5%
Technology
FTEs
Non-Technology
FTEs
16%
>300
250 - 300
150 - 250
100 - 150
50 - 100
25 - 50
1 - 25
11. 11
In our view, institutions cannot
afford to adopt a wait-and-see
approach in their response to
the challenges presented by
GSR. They should act quickly
to seize the opportunity and
not lose time strategically
repositioning the organization,
while remaining focused on
solving for the ongoing pressures
of regulatory compliance.
There is no one solution for responding to this
challenge, and each institution’s response should
be unique to its strengths and weaknesses
as well as its future business expectations.
However, our experience suggests the
following three steps should be considered:
1. Organize a
long-term response
Institutions need to think end-to-end across
regulations and geographies, and be holistic
in assessing and communicating impacts
across the business and operating model,
both to streamline the change response and
to identify smart investments. Ninety-six
percent of the 2015 Global Structural Reform
Study respondents cite the definition of a
clear strategy and objectives as important
to driving an effective response.
Accenture sees seven major pillars
of structural reform that are forcing
change across each jurisdiction in which
financial institutions operate. These can
provide a framework for developing a
longer-term plan. The chart that follows
identifies the pillars and highlights some
of the key regulatory requirements these
structural reforms help address.
Unlock the Potential of GSR
12. 12
Scrutiny from
Domestic Regulations
Governance
of Legal Entities
Stricter
Stress Testing
Description Institutions have less jurisdictional
flexibility and need to solve
for each set of requirements
within the countries in which
they operate. This is critical
for addressing the bespoke
expectations of each regulator.
Institutions need to address and
manage these requirements both
today and in a sustainable manner
going forward.
Institutions need to think
about how legal entities will be
governed in the jurisdictions
they continue to operate in,
potentially requiring a shift
in ultimate responsibility for
daily operations of the business
between an institution’s global
parent and the geographic legal
entity structure.
Institutions face an increase in
the requirements to evidence
comprehensive and effective risk
management, as confirmed by
recent feedback from the Federal
Reserve’s 2015 stress testing at
the legal entity level.9
Regulators
are increasingly focused on
comprehensive risk reporting
by legal entity, in turn placing
emphasis on the quality and
completeness of institutions’ data
architecture.
Example of
Regulatory
Requirements
• Securities and Exchange
Commission 15a-6 requires a
revised control framework.
• The Federal Financial
Institutions Examination
Council call reporting.
• Alternative Investment Fund
Managers Directive creates
regulations on alternative
investment funds.
• Markets in Financial
Instruments Directive
syncs European Union
(EU) investment services
regulations.
• Office of the Comptroller of the
Currency-12 (Code of Federal
Regulations) CFR 30 and 170
establishes a new framework
for risk governance.
• Dodd-Frank (DF) Section
165 mandates that Foreign
Banking Organizations (FBO)
establish senior management
governance, US chief risk
officer, and US risk committee.
• Demand for enhanced
governance and oversight
by the Office of the
Superintendent of Financial
Institutions (OSFI).
• With DF Section 165 FBOs
subject to the same stress
testing requirements as a
domestic US banking entity.
• European Banking Authority
Stress Test provides an EU-
wide stress test methodology
and scenarios.
Seven Pillars of Structural Reform
13. 13
Capital and
Liquidity Adequacy
Recovery and
Resolution Planning
Separation or
Cessation of Activities
Geography
Focused Finance
Local and global regulations
are forcing institutions to
operate within a more capital
restrained environment.
Institutions need to provide
sufficient capital and liquidity
to enable the business
to compete effectively in
the products they opt to
continue offering in the
marketplace. Enterprise-wide
capital planning will be a key
support in allocating capital
as well as evidencing capital
and liquidity adequacy to
regulators.
Regulators are ensuring
stability of banking
operations, for example
making provision for state
takeover in the event an
institution becomes insolvent.
Institutions need to invest
time in developing and
communicating a roadmap to
facilitate recovery or orderly
wind-down.
Certain regulations are
mandating ring-fencing
of assets, for example
between retail deposits and
investment banking activities.
These rules are enabling
greater resilience to allow
one legal entity or business
line to potentially fail without
causing systemic failure
across the enterprise.
Institutions are needing
to consider re-orientation
of their financial ledgers,
performance management,
and reporting to enable
financial operations at the
jurisdiction level.
• Domestic and foreign
entities utilize Basel III to
calculate minimum capital
requirements (FBO home
country standards).
• Collins Amendment sets a
capital requirement floor
at 10%.
• Capital Requirements
Directive IV delivers capital
requirements that reflect
Basel III rules.
• Basel III standards adopted
by OSFI’s Capital Adequacy
Requirements Guideline.
• New Liquidity Coverage
Ratio.
• Provisions made in DF
Section 166 for domestic
US banks, and in DF
Section 165 for Foreign
Banking Organizations
Banking Act 2009 (UK)
requires resolvability,
recovery planning
and provides for bank
nationalization.
• European Banking
Authority issued a
Recovery and Resolution
directive on crisis
prevention to enhance
stability, protect
depositors, and reduce
moral hazard.
• Volcker Rule seeks to cease
proprietary trading.
• The Independent
Commission on Banking
recommends separating
retail deposits from
investment banking
activities.
• Liikanen in the EU seeks
to separate proprietary
trading and strengthen
governance regulations.
• US Enhanced Prudential
Standards requires FBOs to
maintain a debt-to-equity
ratio of no more than 15:1.
• In the US, the Foreign
Account Tax Compliance
Act (FATCA) and the
Standard for Automatic
Exchange of Financial
Account Information
(GATCA) developed by
the Organization for
Economic Cooperation and
Development (OECD).
• COREP/FINREP as part
of the European Banking
Authority’s Capital
Requirements Directive
(CRD) IV.
Source: Accenture analysis based upon publicly available documents, April 2015
15. 15
2. Unlock potential
in a new ecosystem
Once regulatory needs and solutions are
organized, institutions will need to think
immediately about unlocking the potential
value in changes and investments. In the
case of major investments in change,
institutions will need to closely consider
the businesses they want to be in within
this new financial services ecosystem.
It will be too late to react when
regulatory changes have been implemented.
If institutions want to remain competitive
and viable for the long term, the time to
act is now. Our experience would indicate
the following areas may help financial
institutions unlock new opportunities for
sustainment and competitive growth.
• Think local, not global. Institutions
need to consider the type of business
they want to conduct in each of their
locations and the practical operations
required to sustain these businesses
while best managing capital and costs.
For multinational institutions, this would
require aligning global capabilities with
local capabilities in the jurisdictions in
which they operate. This is a live discussion
for many of our 2015 Global Structural
Reform Study respondents, with 57 percent
indicating they will tailor their geographic
footprint in the next two years and half
divesting geographic units, relocating
their headquarters, or business units
(Figures 5 and 6). This shift in focus may
lead to considering new technologies to
help improve efficiency and effectiveness,
or new operational models that are
not as cost, risk and capital-intensive.
For example, we are seeing increased
usage among our clients of managed
services for know your customer (KYC)
and post-trade processing utilities.
• Aim for market-driven specialization.
Institutions can address competitive
challenges by focusing resources and
attention on certain customer, product,
or geographic market segments. Such
specialization can be performed upon the
basis of a common core of capabilities, and
48 percent of 2015 Global Structural
Reform Study respondents indicate that
they are indeed doubling down over the
next two years on core competencies
in response to regulatory change. We
believe the benefit of focusing on core
competencies is greater local market
recognition and competitive advantage.
• Focus on compliance and efficiency.
Reputational risk could be a competitive
advantage in the future, with clients and
customers drawn to firms with strong
ethical reputations that are also efficient
in meeting their needs. To prepare for this
possible opportunity, institutions should
continue to integrate compliance into
their core processes. Expectations from
regulators should continue to increase in
this area, with the Federal Reserve recently
announcing the first examination of US
banks regarding their level of compliance
with the Volcker Rule.10
• Think with an innovation mindset.
Institutions should keep pace or even
outpace niche providers in accessing the
revenue streams that reflect the needs
of today’s customers or clients. In our
experience, digital-driven payments
and portfolio management companies
are capturing greater market share, and
may become material threats to the
longer-term viability of institutions’
business if sufficient planning is not
in place. Sixty-two percent of our
2015 Global Structural Reform Study
respondents are addressing this concern
by planning to launch new products or
services within the next two years.
16. Launch new geographic units
Focus more on core competencies
Implement cost reductions
Launch new products or service lines
Merge or acquire other companies
Increase headcount via utilizing contractors
Divest geographic units
Change pricing structure
Increase headcount via outsourcing
Relocate headquarters or business units
Shutdown product or service line
Change technology target operating model
Decrease headcount
6 5
6
6
6
7
8
10 27
28
26
25 25
25
30
22
22
21
21
14 14
45 18 30 30
3029
29
36
36
25 29 29
3626
26 31
35 35
35
39
37
37
35
28
27 27
34
34
45
8
11
10
14
31
31
40
40
20
3119 19
19
18
17
31
23
23 38
19
39
8
8
10
15
13
16
8
25
32
29
35
26
32
40
33
30
43
35
34
35
29
29
41
30
25
27
21
24
26
15
17
16
9
7
9
13
19
6
9
7
19
17
21
8
23
37
56
27
42
39
50
51
46
37
41
47
42
40
20
13
35
25
26
35
28
30
28
28
17
37
23
33
24
29
21
17
9
11
17
17
15
15
13
15
7
7
9
11
10
16
16
16
16
23
25
7
25
36
42
24
18
36
27
37
36
18
28
27
38
27
30
26
42
45
33
40
28
31
51
40
25
33
34
27
26
24
25
Increase headcount via home office support 527 2610 36 31 33 31 12 54 21 13 16 27 36 22
Implement change management programs 28 26 2414 2932 3216 13 37 28 22 18 30 34 18
21
Increase headcount by hiring permanent staff 2728 2413 1335 40 21 20 35 24 20 7 42 36 16
Tighten risk management 249 3433 13 25 41 22 11 41 30 19 9 39 32 20
18
19
18
16
9
23
22
14
Global
(%) (%) (%) (%)
Banking Capital Markets Insurance
Currently not planned Currently in discussion OngoingPlanned within the next 2 years
16
Figure 5. Industry response to regulatory changes
What specific strategic changes will your organization implement in response to regulatory changes? (Select one)
Note: Due to rounding, total may not equal 100 percent
Source: Accenture 2015 Global Structural Reform Study
18. 18
3. Demonstrate value
to key stakeholders
The value of GSR can only be realized,
in our view if planning is effectively
instituted and adopted throughout
the institution’s business. Broad,
comprehensive stakeholder engagement
is a key principle in mobilizing any
response and for encouraging
stakeholders to focus their energy
on the strategic decisions required
rather than lose confidence through
a lack of understanding. As firms
move past initial compliance, we also
expect to see further tuning of the
new operating model to promote this
engagement and support from internal
and external stakeholders (Figure 7).
Establish compliance and
communicate future strategy
and operating model
Develop foundational
enhancements to address
new structural reforms
Establish revised steady state
governance, processes, technology,
and talent management
Deliver ongoing
enhancements
Design and Early Implementation Embedding and Tuning
New Operating ModelInitial Compliance
Source: Accenture, June 2015
Figure 7. Demonstrating value to key stakeholders
19. 19
GSR is much more than another
set of regulatory requirements.
Institutions should embrace
structural reform with the
bold thinking demanded by the
creation of a new ecosystem
within the financial services
industry. Institutions will need to
move beyond solutions for point
regulations to a more strategic
mindset that accounts for other
competing or complementary forces.
The Accenture 2015 Global
Structural Reform Study
results indicate that financial
institutions still have work to do
to account for the full implications
of GSR in their planning activity.
Our current experience with
clients facing the strategic challenges
of GSR is that there is still time for
effective decision making and
action that can help position
institutions to remain competitive
and viable in the longer term.
Time for Bold, Strategic Thinking