• Peter Rothwell, Partner |

On 4 February, the PRA wrote (PDF 448 KB) to firms with the outcomes of its 12 October request (PDF 354 KB) for specific firms to provide information on their operational readiness for a zero or negative Bank rate, or a tiered system of remuneration.

The PRA stressed that this letter (and the earlier information request) should not be taken as an indication that the setting of a negative Bank rate is “imminent or indeed a prospect at any time”.

However, on the basis of feedback provided, the PRA concluded that:

  • Firms are already able to deal with near-zero rates (to at least two decimal places)
  • A zero bank rate would pose less of a challenge than a negative rate and would be quicker to implement
  • A small number of firms do not need to do any further development work, but most firms would need to make changes to systems and processes to implement either a tactical or strategic solution
  • The majority of firms would be able to implement tactical solutions to accommodate a negative Bank rate within six months, without material risk to safety and soundness

Following the Monetary Policy Committee (MPC) February meeting (PDF 418 KB) (see paras 67-72), the MPC asked the PRA to engage with firms to ensure that they begin preparations to develop the necessary tactical solutions. Firms are now expected to work towards a position where they are able to implement a negative Bank rate at any point after six months.

At this stage, to avoid the need for reprioritisation, firms are not expected to start work to implement strategic solutions unless these are already in their plans.

What do firms need to do now?

Challenges for firms are multi-dimensional and complex, involving processes, systems and models, contracts and client outreach. Firms must consider:

  • Financial implications – for example impacts on net interest margins, ability to make profits and accrue capital, and financial resilience. Scenario testing will be required to test unknowns
  • Effective governance and key stakeholder engagement – COO, CRO and CFO 
  • Robust project structure and disciplined management 
  • Different elements of the lifecycle:
    • Identification and assessment, including gap analysis 
    • Action and remediation 
    • Testing and assurance