PRA Practitioner Panel: Annual Report 2023/24

Published on 30 July 2024

1: Overview

1.1 The PRA Practitioner Panel (the Panel) is established by the Prudential Regulation Authority (PRA) under sections 2L and 2M of the Financial Services and Markets Act 2000 (FSMA) to represent the interests of practitioners. The Panel is independent of the PRA. The Panel provides input to the PRA to help it meet its statutory objectives and is consulted on the PRA’s general policies and practices relating to either banking or banking and insurance.

1.2 In 2023/24, the Panel continued to effectively represent the interests of practitioners by considering and providing appropriate scrutiny on significant PRA policy and regulatory developments which benefit from the Panel’s input. This has been achieved through regular discussions with the relevant PRA and wider Bank of England (‘the Bank’) policy leads, senior management, and Prudential Regulatory Committee (PRC) members at Panel meetings.

1.3 The Panel has continued to follow the established approach of early engagement in order to add value to the PRA’s approach to policymaking. The Panel is committed to continuing to provide challenge and advice to the PRA, ensuring that practitioners’ views are appropriately considered.

1.4 Following provisions of the Financial Services and Markets Act 2023 coming into force, a new Insurance Practitioner Panel was established in October 2023 and the Insurance Sub-Committee (the ISC) of the Panel was dissolved. As a result of this statutory change, the Insurance Practitioner Panel produces a separate annual report. The activities of the ISC for the period March to October 2023 are covered in the annual report of the IPP. Relevant information continues to be shared between both panels.

Panel membership – as at 29 February 2024

  • Helen Pickford, UK Chief Financial Officer, Zurich Insurance Group – Association of British Insurers (Practitioner Panel Chair)
  • Muir Mathieson, Treasurer, Nationwide Building Society – Building Societies Association (Deputy Chair)
  • Andrew Stoker – Association of British Insurers
  • Caroline Domanski, Chief Executive Officer, No1 CopperPot Credit Union – Great Britain Credit Unions Association
  • Chris Bannister, General Manager, Europe and Americas, Westpac Banking Corporation UK Finance
  • Julia Dunn, UK Chief Risk Officer, HSBC UK Finance
  • Megan McDonald, Chief Executive Officer, Daiwa Capital Markets Europe Association of Foreign Banks
  • Rakesh Thakrar, Chief Financial Officer, Phoenix Group Association of British Insurers
  • Richard Wilson, Chief Executive Officer, Personal Abrdn, – Personal Investment Managements & Financial Advice Association (PIMFA)
  • Ruairi O’Healai, Managing Director, Morgan Stanley Investment Management – The Investment Association
  • Tonia Lovell, Director of Risk Management and Society Secretary, Bath Building Society – Building Societies Association
  • Vacancy – Northern Ireland Credit Unions
  • Vacancy – The Institute of Chartered Accountants in England and Wales (ICAEW)/The Institute of Chartered Accountants of Scotland (ICAS)
  • Vicky Davies, Chief Executive Officer, Northern Bank Limited – UK Finance

1.5 As outlined in the Panel’s Terms of Reference, members serve for a three-year term with the opportunity to extend for an additional term. Over the reporting period, there were a number of changes to the Panel’s membership, which are detailed below.

1.6 During the reporting period, three members of the Panel completed their second terms and stepped down from the Panel. Two members were appointed to replace these members, with the appointment of the third still to be completed. Mary Anne Daly’s second term came to an end and the Personal Investment Management & Financial Advice Association successfully nominated Richard Wilson as a replacement. Bill Smith completed his second term as the member nominated by the Association of Foreign Banks, and was replaced by Megan McDonald. Martin Fisher completed his second term. The process to appoint a replacement as the Northern Irish Credit Unions nominated member is expected to be completed early in the next reporting period.

1.7 Two members of the Panel stepped down from their positions during the reporting period. Bruce Fletcher resigned from his position. He was replaced on the Panel by Julia Dunn, who was nominated by UK Finance. Javier Faiz also stepped down from the Panel, with the Institute of Chartered Accountants in England and Wales yet to nominate a replacement.

1.8 In addition, Chris Bannister was appointed for a second term. Caroline Domanski joined the Panel after being nominated by the Great Britain Credit Unions Association to replace Robert Kelly (Association of British Credit Unions) who stepped down from the Panel in November 2022.

1.9 Throughout the reporting period Helen Pickford continued to serve as chair of the Panel. Muir Mathieson was appointed as the deputy chair.

2: Panel engagement with the PRA

2.1 As planned, the Panel met six times during the reporting period. As in prior years, meetings were attended by senior executives from the PRA and policy areas of the Bank of England, as well as the PRA Chief Executive Officer (CEO) when possible. Key outcomes and insights from these meetings were fed back to relevant decision-makers and policy leads, contributing to the policy making process.

2.2 The PRA CEO continues to hold bilateral meetings with the Panel Chair to discuss the Panel’s views and other relevant issues.

Examples of items considered by the Panel and impact on the PRA

2.3 The following items are examples from the reporting period where the Panel’s views were sought and provided significant added value to the policy process.

Issue

Description

The Strong and Simple framework

The Panel was consulted on matters relating to the PRA’s Strong and Simple initiative for the prudential framework. Discussions were held on Strong and Simple Phase 1, covering liquidity and disclosure, and Phase 2 proposals, which addressed the capital framework.

Review of the Senior Manager and Certification Regime

The Panel provided feedback on the PRA’s review of the Senior Manager and Certification Regime. Members considered points relating to the scope, proportionality and effectiveness of the Regime.

Publication of a Dear CEO letter to Signal Expectations on Issuing Different Forms of Digital Money to Retail Customers

The Panel discussed a proposed Dear CEO letter highlighting the risks that could arise if deposit takers offer multiple digital money products and the ways these risks could be the mitigated. Members reflected on the timing of the letter’s publication and on the focus of the detail included.

Policy Approach to Critical Third Parties

The Panel provided insight on the subject of Critical Third Parties as they relate to operational resilience. Members commented on the proposed direction of the policy, its impact on the operational resilience of both firms and FMIs and whether all the required subjects were adequately addressed in the policy.

Update on Artificial Intelligence by PRA regulated firms

The topic of Artificial Intelligence returned to the Panel in the reporting period. The Panel’s views were sought on the proposed approach to Artificial Intelligence following the responses to the discussion paper (DP)5/22 – Artificial Intelligence and Machine Learning and the publication of the feedback statement FS2/23Artificial Intelligence and Machine Learning.

Update on implementation of the Basel 3.1 standards in the UK

The Panel considered the PRA’s approach to the implementation of Basel 3.1 standards. The Panel expressed views on the policy approach and the associated consultation process.

3: Panel forward agenda

3.1 The Practitioner Panel is scheduled to meet six times in the 2024/25 reporting period. The forward agenda will continue to be shaped by Panel members, and the PRA Executive and senior management team. The focus of the agenda will continue to include items prior to their wider consultation paper publication. However, some topics discussed during the course of the reporting period are expected to return to the Panel as they continue to develop. The agenda will also include any emerging and urgent issues that would benefit from a Panel discussion, as determined by the Panel or at the request of the PRA.