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Accenture 2015 Global Structural Reform Study
Unlocking the Potential of
Global Structural Reform
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
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 thefinancial 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 tothis
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 andgeographies,
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 thelong
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.
4
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, relianceon 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 arestarting to tailortheir 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
5
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
>$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 andthe
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).
16%
13%
16%
20%
27%
20%
17% 18%
23%
16%
10%
4%
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%
22%
21%
21%
11%
8%
18%
18%
7% 16%
35%
34%
31% 25%
11%
29%
15%
15%
24%5% 24% 22% 26%
26%
6% 20% 28% 25% 21%
23%
23%
22%
17%30%
34%
18%11% 15% 30% 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 6%
Assessed the impact on business
Projects rolled out
Reviewed the regulation
Identified projects
Assessed the impact on business 8%
Projects rolled out 8%
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%
Dodd-Frank
Section 165/6
Not yet stated Planning Implementing Compliant
Assurance/validating project
functionality (QA process)
Reviewed the
regulation
7% 17% 28% 24% 24%
Projects rolled out 7% 16% 30% 22% 24%
Identified projects 7% 17% 26% 28% 22%
Reviewed the regulation 16% 26% 30% 7% 21%
Identified projects 2% 14% 37
%
29% 19%
Projects rolled out 4% 14% 48% 17% 17%
Assessed the impact on
business
4% 34% 29% 17% 15%
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?
Technology
FTEs
Non-Technology
FTEs
>300
250 - 300
150 - 250
100 - 150
50 - 100
25 - 50
1 - 25
20%
25%
15%
17%
8%
18%
16%
11%10%
22%
25%
5%
4% 3%
9
10
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
Scrutiny from
Domestic Regulations
Governance
of Legal Entities
Stricter
Stress Testing
Description Institutions haveless 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
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
14
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 indicatethe
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.
Launch new geographic units
Implement cost reductions
Launch new products or service lines
Merge or acquire other companies
Divest geographic units
Change pricing structure
Shutdown product or service line
Decrease headcount
5
6
6
Focus more on core competencies 7
28 25 25 30
29
Change technology target operating model 6 36
8 26 36
10 27 35 35
35 22
28 22
27
14 34
Increase headcount via utilizing contractors 8 35
11 39
10 37
Increase headcount via outsourcing 14
Relocate headquarters or business units 19
8 27 29
31 21 10 35
21 37 23 19 16 40
40 18 8 33
7
34 21 7
29 15 21
19 39
47
41 17 8 42
25 29 29 17 25 30 30 16 23 40
9 27 35 29
7
7
17 15
37 13 7
23 15
9 24
10 36
16 36
42 24
Increase headcount via home ofice support 10 36 33 31 12 54 16 27 36 22
Implement change management programs 14 32 28 26 16 29 32 24
33 21
Increase headcount by hiring permanent staV 28 2413 35 21 27 36 16
Tighten risk management 9 33
27 26 5 31
14 31
34 24 13 25
13 40
41 22 11 41
21 13
26 17
30 19 9 39
20 35 24 20 7 42
32 20
31 18
25 27 25 23
25 27 34 14
Global
(%)
6 36 26 31
Banking
(%)
Capital Markets
(%)
9 37 20 33
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
45 18 30
34 23 38
45 19 30
25 39 30
56 13 24
46 30 17
36 30 27
42 26 26
13 42 25 21 11 18 45 25
13 37 28 22 18 30 34 18
32 43 25 6 50 35 9 16 27 40 18
8 29 35 27 9 51 28 1
1
16 37 28 19
26 40 20 1
5
26 35 24 19 37 28 17 16 18 51 16
31 31 19 13 32 29 26 17 41 28 15 23 28 40 9
38 33 22
7
8 35
11 39
10 37
3
35 22 6 52
28 22 14 31
9 41 9 41
3
11
31 21 13 27 33 27 13
53
39 3 8 32
41 14 14 43
13 18 45
13 24 32
24
32
24 13 7
24 19 3
37 24 7 30
50 20
30 33
7
3 34
14 46
30 30
11 25 36
34
31 31
33
10 36 27 26 10 43 30 17 5 41 41 14 20 37 18 25 14 43
14 32 28 26 6 32 39 23
7 23
26 26 24 24 10 37 23 30
10 33
11 33 26 30
28 2413 35 13 55 29 3 7 25 21 21 32
9
29
21 18
1 36
14 26 40 20 6 2 22 26
19 31 31 19 18 43 21 18 11 42 34 13 23 13 37 27 29 21 29 21
Global
(%)
6 36 26 31
Asia Pacific
(%)
Latin America
(%)
North America
(%)
10 24 41 24
Europe
(%)
10 48 7
Figure 6. Regional response to regulatory changes
What specific strategic changes will your organization implement in response to regulatory changes? (Select one)
21 37 23 19 20 37 17 27 26 47 16 11 24 21 34 21 11 41 26 22
6 36 40 18 3 30 47 20 11 39 34 16 3 38 41 17 7 34 38 21
25 29 29 17 20 23 37 20 21 39 32 8 34 21 21 24 26 30 26 19
Note: Due to rounding, total may not equal 100 percent
Source: Accenture 2015 Global Structural Reform Study
45 18 30
32 35 29
8 26 36 29 13 25 31 31
1
0
27 35 27 13 33
30
23
32 52 1
0
39 21 37
48 14 31
30 37 33
33 27 37
47 29 11 7 37 40 17 7 36 2
1 18 42 18 10 23 40 27 19 33
36 25 39
6 39 26 29 17 37 40
1
4
34 28 25 1
3
30 27 30 13 50 24 13 10
21
41 28 18 2
9
21 32
33 34 24 10 39 23 29 13 42 34 11 1017 47 27 4 32 32 32
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
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
References
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banks-can-find-opportunity-in-a-flood-of-
regulations-1071090-1.html
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rbc-nr.html
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barclayspublic/docs/InvestorRelations/IRN
ewsPresentations/2014Presentations/15-
may-barclays-group-strategy-update.pdf
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bofa-said-to-oust-150-hedge-fund-
clients-under-new-rules
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4e43-11e4-adfe-00144feab7de.
html#axzz3VtU6lJPD (access required)
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Revolutionizing Banking and the Customer
Ecosystem,” Accenture, January 2014.
Accessed at: http://www.accenture.
com/SiteCollectionDocuments/financial-
services/accenture-everyday-bank.PDF
9.“Big Banks Struggle to Pass Fed’s ‘Stress
Tests’,” Wall Street Journal, March 11, 2015.
Accessed at: http://www.wsj.com/articles/
federal-reserve-rejects-2-banks-capital-
plans-in-annual-stress-tests-1426105804
(access required)
10.“Volcker rule exam will look into banks’
structural data,” SmartBrief on Risk and
Compliance, March 10, 2015. Access at:
https://www2.smartbrief.com/servlet/
ArchiveServlet?issueid=25AC25BB-87AB-
420E-8DC3-5FD50869CE72&lmid=archives
About the Authors
Samantha Regan is a Managing Director in
Accenture’s Finance & Risk Services. Shehas
17 years of global experience working with
C-suite executives and their businesses in
compliance and regulatory initiatives.
Samantha is the North America Lead for
the Regulatory Remediation & Compliance
Transformation group within Accenture’s
Finance & Risk Services practice.
samantha.regan@accenture.com
Venetia Woo is a Senior Manager in
Accenture’s Finance & Risk Services, and
serves as the offerings lead for both Global
Structural Reform and Prudential Standards.
She has extensive experience in leading
restructuring, M&A and joint ventures
formation activities for financial institutions.
Venetia also specializes in advising large
institutions in credit risk, counterparty and
capital adequacy functions and is the co-
author of “The Effectiveness of Regulatory
Stress Testing Disclosures.”
venetia.w.woo@accenture.com
Ben Shorten is a Senior Manager in
Accenture’s Finance & Risk Services, and
serves as the Strategy and Target Operating
Model offering lead for Regulatory Remediation &
Compliance Transformation in North America.
He has extensive experience working
with C-Suite executives and their executive
committees in Tier I investment banks and
leading retail banking institutions in both the
UK and the US to define and mobilize complex
change delivery in response to government
and regulatory mandate to change.
benjamin.j.shorten@accenture.com
Chris Beck is a Manager in Accenture’s Finance
& Risk Services. Specialized in strategy
planning, surveillance, operational risk
management and compliance risk
management, Chris brings his solid experience
and skills in these areas to help financial
institutions define and implement their
governance and risk management structures.
christopher.t.beck@accenture.com
Acknowledgements
The authors would like to thank Craig
Unterseher, Laura Bishop, Haralds Robeznieks
and Evan Goldsmith for their contribution to
this document.
About Accenture
Accenture is a global management
consulting, technology services and
outsourcing company, with more than
323,000 people serving clients in more
than 120 countries. Combining unparalleled
experience, comprehensive capabilities
across all industries and business functions,
and extensive research on the world’s
most successful companies, Accenture
collaborates with clients to help them
become high-performance businesses and
governments. The company generated net
revenues of US$30.0 billion for the fiscal
year ended Aug. 31, 2014. Its home page is
www.accenture.com.
Disclaimer: This document is intended for general
informational purposes only and does not take into
account the reader’s specific circumstances, and
may not reflect the most current developments.
Accenture disclaims, to the fullest extent permitted
by applicable law, any and all liability for the
accuracy and completeness of the information in this
document and for any acts or omissions made based
on such information. Accenture does not provide
legal, regulatory, audit, or tax advice. Readers are
responsible for obtaining such advice from their own
legal counsel or other licensed professionals.
Stay Connected
Accenture Finance & Risk Services:
http://www.accenture.com/microsites/
financeandrisk/pages/index.aspx
Connect With Us
https://www.linkedin.com/
groups?gid=3753715
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Copyright ©2015 Accenture
All rights reserved.
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High Performance Delivered
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Accenture 2015 Global Structural Reform Study

  • 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 thefinancial 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 tothis 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 andgeographies, 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 thelong 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.
  • 4. 4
  • 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, relianceon 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 arestarting to tailortheir 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 5
  • 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 >$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 andthe 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). 16% 13% 16% 20% 27% 20% 17% 18% 23% 16% 10% 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% 22% 21% 21% 11% 8% 18% 18% 7% 16% 35% 34% 31% 25% 11% 29% 15% 15% 24%5% 24% 22% 26% 26% 6% 20% 28% 25% 21% 23% 23% 22% 17%30% 34% 18%11% 15% 30% 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 6% Assessed the impact on business Projects rolled out Reviewed the regulation Identified projects Assessed the impact on business 8% Projects rolled out 8% 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% Dodd-Frank Section 165/6 Not yet stated Planning Implementing Compliant Assurance/validating project functionality (QA process) Reviewed the regulation 7% 17% 28% 24% 24% Projects rolled out 7% 16% 30% 22% 24% Identified projects 7% 17% 26% 28% 22% Reviewed the regulation 16% 26% 30% 7% 21% Identified projects 2% 14% 37 % 29% 19% Projects rolled out 4% 14% 48% 17% 17% Assessed the impact on business 4% 34% 29% 17% 15%
  • 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? Technology FTEs Non-Technology FTEs >300 250 - 300 150 - 250 100 - 150 50 - 100 25 - 50 1 - 25 20% 25% 15% 17% 8% 18% 16% 11%10% 22% 25% 5% 4% 3%
  • 9. 9
  • 10. 10
  • 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 haveless 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
  • 14. 14
  • 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 indicatethe 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 Implement cost reductions Launch new products or service lines Merge or acquire other companies Divest geographic units Change pricing structure Shutdown product or service line Decrease headcount 5 6 6 Focus more on core competencies 7 28 25 25 30 29 Change technology target operating model 6 36 8 26 36 10 27 35 35 35 22 28 22 27 14 34 Increase headcount via utilizing contractors 8 35 11 39 10 37 Increase headcount via outsourcing 14 Relocate headquarters or business units 19 8 27 29 31 21 10 35 21 37 23 19 16 40 40 18 8 33 7 34 21 7 29 15 21 19 39 47 41 17 8 42 25 29 29 17 25 30 30 16 23 40 9 27 35 29 7 7 17 15 37 13 7 23 15 9 24 10 36 16 36 42 24 Increase headcount via home ofice support 10 36 33 31 12 54 16 27 36 22 Implement change management programs 14 32 28 26 16 29 32 24 33 21 Increase headcount by hiring permanent staV 28 2413 35 21 27 36 16 Tighten risk management 9 33 27 26 5 31 14 31 34 24 13 25 13 40 41 22 11 41 21 13 26 17 30 19 9 39 20 35 24 20 7 42 32 20 31 18 25 27 25 23 25 27 34 14 Global (%) 6 36 26 31 Banking (%) Capital Markets (%) 9 37 20 33 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 45 18 30 34 23 38 45 19 30 25 39 30 56 13 24 46 30 17 36 30 27 42 26 26 13 42 25 21 11 18 45 25 13 37 28 22 18 30 34 18 32 43 25 6 50 35 9 16 27 40 18 8 29 35 27 9 51 28 1 1 16 37 28 19 26 40 20 1 5 26 35 24 19 37 28 17 16 18 51 16 31 31 19 13 32 29 26 17 41 28 15 23 28 40 9 38 33 22
  • 17. 7 8 35 11 39 10 37 3 35 22 6 52 28 22 14 31 9 41 9 41 3 11 31 21 13 27 33 27 13 53 39 3 8 32 41 14 14 43 13 18 45 13 24 32 24 32 24 13 7 24 19 3 37 24 7 30 50 20 30 33 7 3 34 14 46 30 30 11 25 36 34 31 31 33 10 36 27 26 10 43 30 17 5 41 41 14 20 37 18 25 14 43 14 32 28 26 6 32 39 23 7 23 26 26 24 24 10 37 23 30 10 33 11 33 26 30 28 2413 35 13 55 29 3 7 25 21 21 32 9 29 21 18 1 36 14 26 40 20 6 2 22 26 19 31 31 19 18 43 21 18 11 42 34 13 23 13 37 27 29 21 29 21 Global (%) 6 36 26 31 Asia Pacific (%) Latin America (%) North America (%) 10 24 41 24 Europe (%) 10 48 7 Figure 6. Regional response to regulatory changes What specific strategic changes will your organization implement in response to regulatory changes? (Select one) 21 37 23 19 20 37 17 27 26 47 16 11 24 21 34 21 11 41 26 22 6 36 40 18 3 30 47 20 11 39 34 16 3 38 41 17 7 34 38 21 25 29 29 17 20 23 37 20 21 39 32 8 34 21 21 24 26 30 26 19 Note: Due to rounding, total may not equal 100 percent Source: Accenture 2015 Global Structural Reform Study 45 18 30 32 35 29 8 26 36 29 13 25 31 31 1 0 27 35 27 13 33 30 23 32 52 1 0 39 21 37 48 14 31 30 37 33 33 27 37 47 29 11 7 37 40 17 7 36 2 1 18 42 18 10 23 40 27 19 33 36 25 39 6 39 26 29 17 37 40 1 4 34 28 25 1 3 30 27 30 13 50 24 13 10 21 41 28 18 2 9 21 32 33 34 24 10 39 23 29 13 42 34 11 1017 47 27 4 32 32 32
  • 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
  • 20. References 1. “How Banks Can Find Opportunity in a Flood of Regulations,” American Banker, November 10, 2014. Accessed at: http:// www.americanbanker.com/bankthink/how- banks-can-find-opportunity-in-a-flood-of- regulations-1071090-1.html 2. “Banking 2020: As the Storm Abates, North American Banks Must Chart a New Course to Capture Emerging Opportunities,” Accenture, October 2013. Accessed at: http://www.accenture.com/ SiteCollectionDocuments/PDF/Accenture- Banking-2020-POV.pdf 3. “RPT-Deutsche Bank bets big on U.S. for investment bank growth,” Reuters, March 2, 2015. Accessed at: http://www.reuters. com/article/2015/03/02/deutschebank- outlook-idUSL5N0W41S320150302 4. RBC to acquire City National Corporation, a premier U.S. private and commercial bank,” Royal Bank of Canada news release,January 22, 2015. Accessed at: http://www. rbc.com/newsroom/news/2015/20150122- rbc-nr.html 5. “Barclays PLC: Group Strategy Update – Building Barclays as the ‘Go-To’ bank,” Barclays, May 8, 2014. Accessed at: http://www.barclays.com/content/dam/ barclayspublic/docs/InvestorRelations/IRN ewsPresentations/2014Presentations/15- may-barclays-group-strategy-update.pdf 6. “BofA Said to Oust 150 Hedge Fund Clients Under New Rules,” BloombergBusiness, January 13, 2015. Accessed at: http://www. bloomberg.com/news/articles/2015-01-13/ bofa-said-to-oust-150-hedge-fund- clients-under-new-rules 7. “Shrinking margins and higher costs drive down investment banks’ returns”, Financial Times, November 4, 2014. Accessed at: http://www.ft.com/intl/cms/s/0/1ebb3d1c- 4e43-11e4-adfe-00144feab7de. html#axzz3VtU6lJPD (access required) 8. “The Everyday Bank – How Digital is Revolutionizing Banking and the Customer Ecosystem,” Accenture, January 2014. Accessed at: http://www.accenture. com/SiteCollectionDocuments/financial- services/accenture-everyday-bank.PDF 9.“Big Banks Struggle to Pass Fed’s ‘Stress Tests’,” Wall Street Journal, March 11, 2015. Accessed at: http://www.wsj.com/articles/ federal-reserve-rejects-2-banks-capital- plans-in-annual-stress-tests-1426105804 (access required) 10.“Volcker rule exam will look into banks’ structural data,” SmartBrief on Risk and Compliance, March 10, 2015. Access at: https://www2.smartbrief.com/servlet/ ArchiveServlet?issueid=25AC25BB-87AB- 420E-8DC3-5FD50869CE72&lmid=archives About the Authors Samantha Regan is a Managing Director in Accenture’s Finance & Risk Services. Shehas 17 years of global experience working with C-suite executives and their businesses in compliance and regulatory initiatives. Samantha is the North America Lead for the Regulatory Remediation & Compliance Transformation group within Accenture’s Finance & Risk Services practice. samantha.regan@accenture.com Venetia Woo is a Senior Manager in Accenture’s Finance & Risk Services, and serves as the offerings lead for both Global Structural Reform and Prudential Standards. She has extensive experience in leading restructuring, M&A and joint ventures formation activities for financial institutions. Venetia also specializes in advising large institutions in credit risk, counterparty and capital adequacy functions and is the co- author of “The Effectiveness of Regulatory Stress Testing Disclosures.” venetia.w.woo@accenture.com Ben Shorten is a Senior Manager in Accenture’s Finance & Risk Services, and serves as the Strategy and Target Operating Model offering lead for Regulatory Remediation & Compliance Transformation in North America. He has extensive experience working with C-Suite executives and their executive committees in Tier I investment banks and leading retail banking institutions in both the UK and the US to define and mobilize complex change delivery in response to government and regulatory mandate to change. benjamin.j.shorten@accenture.com Chris Beck is a Manager in Accenture’s Finance & Risk Services. Specialized in strategy planning, surveillance, operational risk management and compliance risk management, Chris brings his solid experience and skills in these areas to help financial institutions define and implement their governance and risk management structures. christopher.t.beck@accenture.com Acknowledgements The authors would like to thank Craig Unterseher, Laura Bishop, Haralds Robeznieks and Evan Goldsmith for their contribution to this document. About Accenture Accenture is a global management consulting, technology services and outsourcing company, with more than 323,000 people serving clients in more than 120 countries. Combining unparalleled experience, comprehensive capabilities across all industries and business functions, and extensive research on the world’s most successful companies, Accenture collaborates with clients to help them become high-performance businesses and governments. The company generated net revenues of US$30.0 billion for the fiscal year ended Aug. 31, 2014. Its home page is www.accenture.com. Disclaimer: This document is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. 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