Prudential regulation

ADM can assist clients with their ongoing implementation of Basel III through the EU regulation directives and/or regulations that are currently in force (CRD IV/CRR), or in train, including the upcoming CRD V/CRR II and the new prudential regime for investment firms (both of which are expected to be formally adopted in Q2/Q3 2019 with measures coming into force in 2021). Areas of particular focus are those measures relating to credit, operational and liquidity risk, as well as the client’s dialogue with relevant regulatory authorities on Pillar 2.

ADM can also review client Internal Capital Adequacy Assessment Process (ICAAP) submissions as well as the governance and structure of client ICAAP programmes.

Our experience with Basel III dates back to Anita Millar’s work as an interim Managing Director at the Association for Financial Markets in Europe (AFME) (Feb 2010–Jul 2011), where she worked with AFME’s membership to develop and communicate AFME’s positions on a number of Basel III/crisis management initiatives relating to the Basel Committee’s capital and liquidity proposals, prudential aspects of the developing debate on systemically important financial institutions (SIFIs), and the role that enhanced supervision, contingent capital and bail-in could play in responding to the systemic concerns of the G20.

As part of the contract with AFME, ADM also led AFME’s advocacy activities on Basel III/CRD IV, which included representing AFME (as a member of the Global Financial Markets Association (GFMA)) at senior industry outreach meetings organised by the Basel Committee, and organising and leading delegations of AFME members to meet with EU officials in Brussels, and treasury/central bank officials in EU member state capitals.

Following this time at AFME, Anita Millar worked on an interim basis for a major UK bank (Oct 2013–May 2014), tracking changes in prudential regulation, and then for a leading UK asset manager (Apr 2017–Apr 2018) submitting amendments on CRR II to MEPs (which were aimed at addressing the interplay between the prudential regime and the pension fund exemption from central clearing in EMIR).