Minutes of the Meeting of the Court of Directors held on 5 July 2024

Minutes of the Meeting of the Court of Directors held on 5 July 2024

Present:

David Roberts, Chair

Andrew Bailey, Governor

Sarah Breeden, Deputy Governor – Financial Stability

Clare Lombardelli, Deputy Governor – Monetary Policy

Sam Woods, Deputy Governor – Prudential Regulation

Jonathan Bewes

Sabine Chalmers

Lord Jitesh Gadhia

Anne Glover

Sir Ron Kalifa

Diana Noble

Tom Shropshire

In attendance:

Ben Stimson, Chief Operating Officer

Apologies:

Sir Dave Ramsden, Deputy Governor – Markets & Banking

Frances O’Grady

Secretary:

Sebastian Walsh

1. Conflicts, Minutes and Matters Arising

There were no conflicts declared in relation to the present agenda.

The minutes of the meeting held on 22 May 2024 were approved.

The Chair welcomed Clare Lombardelli to first meeting of Court, since formally taking up the position of Deputy Governor for Monetary Policy.

The Chair set out that the next Court Away Day would be held in the second half of the year. Members thought the topic of payments would be a valuable focus for the meeting. The Chair also proposed to hold a meeting of Court at the Bank’s Leeds office in 2025, which was welcomed by Court.

The Chair noted that the Bank’s Annual Report and Accounts would be published as soon as possible, following the General Election. Alongside this, the Bank was due to publish its refreshed strategy for Data and Analytics. The Chair noted that he would – as previously agreed – be asked to approve this for publication in due course.

2. Governor’s Update

The Governor observed that the Court meeting took place shortly after the General Election in the UK. The Governor explained that there had been no discernible market reaction to the outcome of the General Election.

The Governor highlighted to Members of Court that a number of the Bank’s public appointments had been paused or delayed due to the General Election, in line with Cabinet Office Guidance.

The Governor noted that the Executive was assessing the Bank’s strategic priorities for the next three years, proposals for which would return to Court in due course. The Governor also highlighted progress in the development of the Bank’s new office in Leeds, which members of Court welcomed. Court members observed the importance of ensuring the Bank’s key committees, for instance Court, held meetings in Leeds.

3. Audit and Risk Committee (ARCo) Update

Jonathan Bewes updated Court on the most recent meeting of ARCo, held on 21 June 2024.

In the Audit section of the meeting, Jonathan Bewes informed Court that ARCo had commissioned a study in relation to the updated UK Corporate Governance Code, which would return to the sub-committee in the autumn. He added that ARCo would receive an update on the Finance Modernisation Programme at its October meeting.

Jonathan Bewes said that ARCo had been reassured that the Bank’s outgoing external auditors, KPMG, had found the Bank had made progress against issues identified the previous year. He said that the Bank’s new auditor, EY, was due to return to ARCo in October with its full audit plan and that transition arrangements between EY and KPMG were proceeding as planned.

Internal Audit had presented its annual report to ARCo, noting progress made to enhance the Bank’s controls environment.

In the Risk section of the meeting, ARCo received an update from the Chief Risk Officer.

ARCo received updates on the Bank’s approach to model governance, the 5-year capital review and the Bank’s new Non-Bank Financial Institutions lending tool. The Bank’s Chief Information Officer – Nathan Monk – and Head of Cyber – Jonathan Pagett – also updated ARCo on work underway in their respective areas.

4. Remuneration Committee (RemCo) Update

Diana Noble updated Court on the work of RemCo and topics discussed at its most recent meeting on 12 June 2024.

5. Nominations Committee (NomCo) – oral update

The Chair set out that NomCo met after the last meeting of Court, on 22 May 2024.

NomCo had approved an appointment to the Board of the Bank’s Pension Trustees.

NomCo had also been updated on the Bank’s skills and talent programme. NomCo agreed that good progress had been made with regards to the foundational elements of the programme.

6. Chief Operating Officer Update

Ben Stimson updated Court on key developments since its last meeting, including the launch of the Leeds Strategy and the Pensions Review.

Ben Stimson also highlighted progress in technology modernisation and IT infrastructure. He added that, regarding the modernisation of the Bank’s data processes and systems, progress was in line with expectation.

In response to a question from Tom Shropshire, Ben Stimson agreed that resource constraints were a consistent theme across the organisation. Ben Stimson was hopeful that the completion of the RTGS Renewal Programme would free up skills and capability to deploy to other areas. Ben Stimson said that the Bank’s capacity to respond to changing demands over time would be improved as a direct result of the work being undertaken by the Change and Planning area.

Ben Stimson informed Court that the RTGS Renewal Programme continued to make significant progress.

Enterprise Demilitarized Zone (DMZ) Programme

Court approved the DMZ Programme update, noting its foundational importance for the technology estate.

ISO 20022 Internal Readiness Programme

Court approved the Programme update, noting its close link to the RTGS Renewal Programme.

Court asked that the Bank’s executive directors do more to draw out the benefits and dependencies of programmes that require Court approval.

7. The Bank’s Finances

(Afua Kyei)

Afua Kyei updated Court on the Bank’s financial position, which was in line with forecasts.

Afua Kyei noted that the Bank would soon announce further details around the operation of the Bank Levy. Court supported the proposed approach to these communications.

8. 5-Year Review of the Bank’s Capital Parameters

(Vicky Saporta, Nick Butt, Aakash Mankodi and Stephen Brown)

Aakash Mankodi introduced the item. He noted the capital framework was a key component of the Bank’s overall financial framework agreed with HM Treasury in 2018 and its parameters were due for review every five years. This was the first of such reviews. He said the Bank felt the framework had operated effectively.

Jonathan Bewes noted that ARCo had discussed the topic at its last meeting and were content to endorse the proposals and recommendations.

Court approved the item.

9. Non-Bank Financial Institution Lending Tool

(Vicky Saporta, Nick Butt, Aakash Mankodi and Stephen Brown)

Nick Butt introduced the item, noting that the tool was designed to support core markets in periods of gilt market dysfunction.  The tool would be launched in two phases, with the first set to go live at the end of this year.  It was then intended to extend coverage across sectors and firms in the second phase of the rollout.  At this meeting, Court’s approval was sought to launch the first phase of the tool.

Nick Butt explained the tool had been designed to reinforce its policy purpose. For example, the tool was contingent – not to be used in normal times – and was market-wide, rather than bilateral.

It was noted that the Bank’s Risk Directorate, Executive Risk Committee and ARCo were content with the risk assessment of the first phase of the tool.

Jitesh Gadhia asked whether the tool could evolve over time. Sarah Breeden noted that it could for example include non-bank entities beyond insurance companies and pension funds, and choices had been made that did not constrain the Bank in assessing the parameters that would set any second phase of the tool.

Court approved the item.

10. Communications Six-Monthly Update

(James Bell and James Hotson)

James Bell introduced the item.

James Bell said polling indicators had improved, with sentiment improving in line with the fall in inflation.

James Hotson set out the Bank’s communications strategy.

Court expressed its support for the Bank’s communications strategy.

11. Court Review of Ethnic Diversity and Inclusion Update February 2024

(Jane Cathrall, Sarah Guerra and Peter Fashesin-Souza)

Sarah Guerra introduced the item, noting that progress had been made against the recommendations of the Court Review.

Diana Noble noted that the Bank had committed to refreshing the analysis underpinning the findings of the Review in 2025 and this update would provide an important foundation for that work.

The Chair summarised the discussion by noting that, while progress had been made following the Court Review, there was risk that it needed further momentum. He added that this would be discussed again by the Nominations Committee later this year.

12. Our Code

(Sebastian Walsh, Michael Salib and Alison Kavanagh)

Court was updated on revisions to the Bank’s “Our Code” booklet, which aimed to create a shorter document that would be easier for staff to engage with. The Secretary noted that one of the key changes was to organise Our Code explicitly around the Seven Principles of Public Life, known as the Nolan Principles. The Chair noted that Our Code would come for final approval at the September meeting.

Non-executive members of Court were supportive of the changes, commending the presenting team for both the new approach and the quality of communication.

Some members noted that it would remain important that all relevant policies were easily accessible through Our Code.

Diana Noble set out that the document explained clearly the expectations the Bank had of its staff, which was appropriate for Our Code. However, she noted that the Bank might consider a separate document that outlined its own commitments and obligations to its staff.

13. Committee Appointment and Conflicts Update

(Sebastian Walsh)

Court noted the paper and discussed future recruitments.

14. Papers for Information

Court noted:

  • Monetary Policy Committee Report
  • RTGS Programme Renewal Update
  • Annual Report and Account Signing Committee Minutes 11 June 2024

The meeting of Court was closed.

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SIMEX 24 – A major market-wide simulation exercise to test the UK financial sector’s resilience to a major operational disruption

News release

The Bank of England, in partnership with UK Finance, the financial sector and the other UK financial authorities (HM Treasury and the Financial Conduct Authority), has undertaken its latest UK market wide simulation exercise, SIMEX 24. The simulation set out to exercise the UK financial sector’s ability to respond to a major infrastructure failure that would require a total shut down and restart of the sector.

SIMEX has been developed and delivered by the Cross Market Operational Resilience Group (CMORG), a strategic partnership between the financial authorities, UK Finance and industry, established by the Bank of England in 2015. It is the latest exercise in a continuous programme that explores the financial sector’s response to some of the most challenging scenarios, including those on the UK Government’s National Risk Register.

The exercise and wider programme to develop financial sector capabilities, supports both the aims of the financial authorities and of firms to ensure collective response tools are in place to respond to disruptive events. This improves the operational resilience of the financial sector and promotes a stable financial system that the public can depend on.

Sam Woods Deputy Governor of Prudential Regulation and CEO of the Prudential Regulation Authority said:

“It is vital to prepare our response to a wide range of risks, including for the most challenging scenarios. SIMEX and the sector exercising programme provide unique opportunities for the whole banking sector, across industry and the authorities, to practise how to protect and defend services on which the economy depends.”

David Postings, Chief Executive of UK Finance, said:

“A resilient financial sector is crucial in a modern economy and a continual area of focus for the financial services industry. The sector-wide exercise this week helps ensure we can respond effectively to any potential incident and protect the UK’s financial system and its customers.”

CMORG enhances the operational resilience of the UK financial sector through collective action, and is supported by specialist industry groups. It achieves this through the identification of systemic risks, the development of solutions to support sector-wide mitigation strategies and sharing capabilities and knowledge across the sector.

As part of this work, CMORG oversees the approach for sector-wide response to systemic incidents through the Sector Response Framework (SRF). The SRF is a key component exercised through SIMEX to ensure the UK’s financial services industry is ready to respond effectively and in a coordinated manner to severe disruption.

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Financial Policy Committee Record – 2024 Q3

Record of the Financial Policy Committee meeting on 19 September 2024

Headline judgements and policy actions

At the FPC’s meeting on 19 September, the Committee also:

1: The Committee met on 19 September 2024 to agree its view on the outlook for UK financial stability. The FPC discussed the risks faced by the UK financial system and assessed the resilience of the system to those risks. On that basis, the Committee agreed its intended policy action.

2: The FPC seeks to ensure the UK financial system is prepared for, and resilient to, the wide range of risks it could face, so that the system is able to absorb rather than amplify shocks and serve UK households and businesses.

Developments in financial markets and vulnerabilities in market-based finance

3: The FPC noted that several factors had contributed to a significant short-lived spike in volatility and falls in equity indices across global financial markets in early August. The release of weaker than expected US jobs data on 2 August had caused markets to reassess expectations of US and global growth. Results for US-tech companies associated with AI had also been weaker than expected. Shifting interest rate differentials between the US and Japan led to the unwind of the Yen carry trade (participants borrowing cheaply in Yen to purchase other assets). Volatility in bond markets rose and implied equity volatility (measured by the VIX) also spiked significantly. The deleveraging of other common trades, including short volatility positions, exacerbated the moves. Such leveraged strategies can amplify volatility when asset prices fall. Most market moves were short-lived, however, in large part due to positive subsequent macroeconomic news, with the majority of equity indices and corporate bond spreads returning to, or close to, their initial levels.

4: In 2024 H1, the FPC had already emphasised the risk of a sharp market correction. In that context, the FPC discussed how to interpret this episode of market volatility. Members emphasised that the evidence of deleveraging behaviour amplifying sharp moves in some markets supported the FPC’s previously communicated view that vulnerabilities in market-based finance (MBF) continued to have the potential to amplify market corrections significantly, which could impact the price and availability of credit for households and businesses. Whilst a broader spillover to core market functioning did not materialise on this occasion, had subsequent macroeconomic news not been positive, further deleveraging could have occurred. MBF vulnerabilities (eg fund liquidity mismatches and hedge fund leverage) remained elevated.

5: Members noted that it was important to understand why the deleveraging behaviour did not spill over materially to core rate markets, including repo markets, which continued to function well. Such a spillover would have posed broader financial stability risks, including by interacting with MBF vulnerabilities to amplify the shock further, and by increasing the cost and availability of credit to households and corporates, increasing refinancing challenges.

6: The FPC discussed the reasons why core markets had remained insulated from the shock, beyond the fact that subsequent macroeconomic news had been positive. First, although levels of margining in certain markets such as equities and foreign exchange had risen sharply, as central counterparties (CCPs) increased margin requirements consistent with the increased volatility, there was a more limited impact across wider financial markets and the size and persistence of the shock was such that firms were sufficiently prepared. No defaults were reported, firms raised no issues with clients’ abilities to meet margin calls, and there were no concerns about counterparty credit, which otherwise may have increased funding pressures. Clearing infrastructure and margining systems were also reported to have operated well amid the sell-off.

7: Second, hedge fund net short positioning in US Treasuries futures was not materially unwound. This had been in contrast to the deleveraging that occurred in March 2020. Widening pressure on the US Treasuries cash-futures basis (the spread between government bond rates and corresponding futures contract) had been mitigated, in this instance, by repo markets continuing to function well, the lack of counterparty credit concerns, and the timing of the episode; the proximity to the futures roll date reduced risk and increased liquidity. This had alleviated the spill-over effects of broader market volatility onto the cash-futures basis trade, reducing deleveraging pressure. Market intelligence had also suggested that these investors had not been materially affected by the unwinding of yen carry trades.

8: Vulnerabilities associated with this trade remained, however. Since the June FSR, hedge fund net short positioning in US Treasuries futures had continued to rise, reaching a new peak of around $1trillion, compared to a previous peak of around $875 billion. Relative to the size of the US Treasury market, this was larger than the previous high reached in 2019. Asset managers had continued to build long positions in Treasuries futures, with hedge funds taking the other side of these positions. Deleveraging of these positions, which had the potential to amplify the transmission of a future stress, could be brought about by several factors, including: if repo market functioning were to deteriorate materially; if counterparty credit risk were to increase; or if investors in the basis trade were to take losses on other positions. It was important for financial institutions to be prepared for such severe but plausible stresses.

9: Measures of equity risk premia (eg the excess cyclically-adjusted price-to-earnings (CAPE) yield) remained close to historical lows in the US, EU, and UK following the episode and risk premia in some other markets were also still compressed. Market contacts noted the apparent disconnect between stretched valuations and risks to global growth, as well as the degree of sensitivity to short-term news. Markets therefore remained susceptible to a sharp correction, with investors sensitive to developments in what remained a challenging global risk environment.

10: Since the June 2024 FSR, both short-term policy rate expectations and longer-term government bond yields had fallen across the US, UK and euro-area, which should lower debt-servicing pressures on borrowers.

Global vulnerabilities

11: The central outlook for UK-weighted global growth had remained broadly unchanged in the Monetary Policy Committee’s (MPC) August Monetary Policy Report (MPR) forecast, with a modest increase in growth projected by the MPC over the medium-term. The FPC judged that global vulnerabilities remained material, as did uncertainty around the central outlook for global growth.

12: As the FPC had previously noted, the current period of elevated geopolitical risk and uncertainty, as well as structural trends such as demographics and climate change, could place further pressure on sovereign debt levels and borrowing costs. High public debt levels in major economies could have consequences for UK financial stability and interact with other risks. A deterioration in market perceptions of the long-term path of public debt globally could lead to market volatility and interact with vulnerabilities in market-based finance, in particular if those markets also feature prominently in leveraged trading strategies. This could lead to a tightening in credit conditions for households and businesses. Increased servicing costs for governments as debt is refinanced could also reduce their capacity to respond to future shocks. The FPC would continue to monitor these risks and take into account the potential for them to crystallise other financial vulnerabilities and amplify shocks.

13: At its 30-31 July meeting, the Bank of Japan had increased its key policy rate to 0.25% and communicated the tapering of its monthly purchases of Japanese government bonds. Recent market volatility underscored potential risks associated with this monetary policy normalisation, which were important for financial institutions to be prepared for. Japanese asset price moves could have an impact in a number of countries globally, for example if the price moves led to substantial reallocations of portfolio holdings across jurisdictions, including emerging market economies. Further rises in domestic yields in Japan could also generate unrealised losses due to interest rate risk on debt security holdings across some Japanese banks.

14: Commercial real estate (CRE) vulnerabilities remained material in advanced economies, in part due to the significant refinancing challenges that remained for CRE borrowers in the higher interest rate environment. Stresses in global CRE markets could affect UK financial stability through several channels, including a reduction in overseas finance for the UK CRE sector.

15: Vulnerabilities in the mainland Chinese property market had continued to crystallise, with new and existing home prices falling further. Commercial and residential property markets in Hong Kong were under pressure from similar factors weighing on markets in other advanced economies but signs of spillovers from vulnerabilities in mainland China remained limited. The 2022/23 ACS results had indicated that major UK banks would be resilient to a severe downturn and very significant declines in property prices in mainland China and Hong Kong.

UK household and corporate debt vulnerabilities

16: The FPC noted that the UK macroeconomic outlook had continued to improve since its 2024 Q2 meeting. The path for UK GDP was a little stronger, and CPI inflation was slightly lower, in the MPC’s August MPR projection relative to the May MPR. In August, the MPC cut Bank Rate by 25 basis points to 5 per cent. The path for Bank Rate expected by market participants over the coming two years had also fallen by around 75 basis points.

17: Overall, mortgagors continued to be resilient to higher interest rates, although some lower income households and renters remained under pressure. Mortgage rates were lower than at the time of the FPC’s Q2 meeting. This would have already started to benefit those on floating rates, who represented around a fifth of borrowers. Given that around a third of mortgagors had not yet refinanced at higher interest rates, however, the aggregate household mortgage debt service ratio (DSR) was still projected to increase, broadly in line with expectations at the time of the June FSR, but remain well below 1990s and global financial crisis (GFC) peaks. The proportion of mortgagors spending more than 70% of the cost-of living adjusted disposable income on mortgage payments was expected to remain broadly flat, well below pre-GFC peaks. Mortgage and consumer credit arrears were largely unchanged since the June FSR and remained low by historical standards.

18: In aggregate, UK corporates had continued to be resilient to the current economic outlook, including high interest rates, with aggregate measures of UK corporate debt vulnerability significantly below their pandemic peaks. The FPC continued to expect them to remain so, but there were still pockets of vulnerability among highly leveraged corporates, including private equity backed businesses, and small and medium sized enterprises (SMEs). Insolvencies had continued to be concentrated among very small businesses associated with a relatively small proportion of bank debt. Firms in more vulnerable sectors such as construction, wholesale and retail trade, and accommodation and food service activities made up around half of cases.

19: While corporate debt issuance had continued to be strong in Q3, a significant portion of market-based UK corporate debt was due to mature in coming years. The challenge faced by corporates that need to refinance their debt could be heightened if recent market volatility translated into a more sustained rise in yields and weaker liquidity. The most highly leveraged and lowest rated corporates were likely to be more exposed to this risk.

UK banking sector resilience

20: The UK banking system remained well capitalised with strong liquidity positions. The aggregate price to tangible book ratio of the major UK banks was around 0.9, suggesting that in aggregate the banks’ expected return on tangible equity was close to their cost of equity. Net interest margins had been stable in Q2 and were expected to remain around long run average levels.

21: There had been further evidence of easing in credit conditions, with gross volumes for mortgage and corporate lending rising to around pre-Covid average levels in Q2. Lending rates continued to move closely in line with expected policy rates. Consistent with changes in the macroeconomic outlook, both credit demand and availability had increased.

22: As the FPC had previously noted, a number of system-wide factors were likely to affect bank funding and liquidity in the coming years, including as central banks normalise their balance sheets, unwinding the extraordinary measures put in place following the GFC and the Covid pandemic. It was important that banks factor these system-wide trends into their liquidity management and planning over the coming years. As part of the normalisation of balance sheets, the MPC had announced it would reduce the stock of asset purchases by £100 billion over the 12 months ahead, £87 billion of which would come through maturing gilt holdings.

23: The FPC noted that usage of the Bank’s short-term repo facility had increased, consistent with the facility’s intended purpose of ensuring interest rate control as the MPC unwinds its asset purchases. The Bank had welcomed banks’ willingness and operational readiness to use this facility, and encouraged lenders to prepare for increased usage of both short-term and long-term repo operations as the Bank of England’s balance sheet moved further through the transition towards a steady state.

24: The FPC maintained its judgement that the UK banking system had the capacity to support households and businesses, even if economic and financial conditions were to be substantially worse than expected.

The UK countercyclical capital buffer rate decision

25: The FPC discussed its setting of the UK countercyclical capital buffer (CCyB) rate. The Committee reiterated that its principal aim in setting the CCyB rate was to help ensure that the UK banking system was better able to absorb shocks without an unwarranted restriction in essential services, such as the supply of credit, to the UK real economy. Setting the UK CCyB rate enables the FPC to adjust the capital requirements of the UK banking system to the changing scale of risk of losses on banks’ UK exposures over the course of the financial cycle. The approach therefore includes an assessment of financial vulnerabilities and banks’ capacity to absorb losses on their UK exposures, including the potential impact of shocks.

26: In considering the appropriate setting of the UK CCyB rate, the FPC discussed its judgements around underlying vulnerabilities that could amplify economic shocks. While the central UK economic outlook had improved slightly, significant financial market and global vulnerabilities remained. But those indicators directly relevant to banks’ UK exposures, including household debt-to-income, corporate gross debt to earnings and domestic credit growth, continued to be around or below long-term averages.

27: The FPC observed that UK banks’ resilience continued to be supported by relatively strong asset quality and strong capital positions. The FPC judged that further signs of easing credit conditions reflected changes to the macroeconomic outlook.

28: In view of these considerations, the FPC decided to maintain the UK CCyB rate at 2%. Maintaining a neutral setting of the UK CCyB rate in the region of 2% would help to ensure that banks continued to have capacity to absorb unexpected future shocks without restricting lending in a counterproductive way.

29: The FPC recognised the continued uncertain environment and reiterated that it would continue to monitor the situation closely and stood ready to vary the UK CCyB rate in either direction – in line with the evolution of economic and financial conditions, underlying vulnerabilities, and the overall risk environment. The results of the Bank’s desk-based stress test exercise, which the committee would discuss in Q4, would further inform the FPC’s monitoring and assessment of the resilience of the UK banking system to downside risks.

2024 review of the FPC’s Leverage Ratio framework

30: In line with its statutory obligations, the FPC reviewed its Direction and Recommendation to the PRA on the leverage ratio, issued in September 2022 and September 2021 respectively.

31: The FPC continued to consider a leverage ratio to be an essential part of the framework for capital requirements for the UK banking system, and judged that the leverage ratio set out in the 2022 Direction and 2021 Recommendation should remain unchanged.

32: Having regard to the interaction between monetary and macroprudential policy, the Committee confirmed the appropriateness of continuing to exclude central bank reserves from the leverage ratio, and of not recalibrating the minimum leverage ratio requirement of 3.25% to reflect an increase in reserves since 2016. The FPC would keep this under review as part of future reviews of the leverage ratio framework.

33: The FPC welcomed the Bank and PRA’s engagement with firms on the normalisation of central bank balance sheets and the financial stability role of central bank reserves, and noted that such discussions would inform future annual FPC reviews of its leverage ratio framework.

34: The FPC noted a PRA announcement that the thresholds for application of the leverage ratio requirement were being reviewed. The Committee would discuss the outcome of this work at a future meeting.

Basel 3.1

35: The FPC welcomed the publication of the PRA’s second near-final policy statement on the implementation of Basel 3.1 standards in the UK on 12 September 2024. The first near-final policy statement was published in December 2023. Together, these publications would implement the final package of prudential reforms developed by the Basel Committee on Banking Supervision in response to the GFC, aligning the UK’s banking system with international standards and promoting its resilience.

Strong and Simple framework

36: The FPC welcomed the PRA’s Consultation Paper – the Strong and Simple Framework: the simplified capital regime for Small Domestic Deposit Takers (SDDTs). The FPC supported the proposal to descope SDDTs from the CCyB and Capital Conservation Buffer to allow the creation of the new Single Capital Buffer (SCB) for these firms. The SCB would simplify the capital regime for SDDTs while maintaining the overall level of resilience. The FPC judged that the UK CCyB would continue to be effective in protecting the supply of credit to the UK real economy, as it would continue to apply to the vast majority of lending by the banking system to UK households and firms.

Resolution framework

37: The FPC noted the published findings of the Bank’s second assessment of the eight major UK banks’ resolvability under the Resolvability Assessment Framework and the conclusion that they provide further reassurance that a major UK bank could enter resolution safely if needed: remaining open and continuing to provide vital banking services, with shareholders and investors—not public funds—first in line to bear the costs of failure. The FPC welcomed the Bank’s continued progress to maintain a credible and effective resolution regime, and to undertake targeted work with firms ahead of the next assessment, as well as the significant progress made by major UK banks in enhancing their preparations for resolution and embedding resolvability within their organisations. Maintaining a credible and effective resolution regime was a continuous process, and both authorities and firms needed to respond as the financial system and regulatory landscape evolves. 

38: The FPC welcomed the introduction of the Bank Resolution (Recapitalisation) Bill to Parliament on 18 July. The FPC supported this targeted enhancement of the UK bank resolution regime in light of the resolution of SVB UK in 2023. The FPC also noted the Bank’s work to operationalise the resolution regime for CCPs, as legislated for by Parliament in 2023. This helped to ensure resolution arrangements across the financial sector were credible, effective, and proportionate.

Operational resilience

39: The FPC was updated on progress by firms and FMIs towards implementing the operational resilience policies set by the Bank, PRA and FCA. The policies required relevant firms and FMIs to identify important business services and set impact tolerances with consideration to financial stability in terms of the wider financial sector and UK economy. Firms and FMIs were expected to demonstrate their ability to meet the policies by 31 March 2025.

40: Despite progress, firms and FMIs must continue to address vulnerabilities and ensure that they can remain within impact tolerances even under severe but plausible scenarios. The FPC noted that they must focus on their roles in the financial system and broader economy, and engage with other firms, other FMIs and the wider market on the potential impact of their own disruption and actions they might take in response to disruption.

41: The FPC further noted that building resilience to operational risks is a continuous process, and that it would continue to monitor how the progress of firms and FMIs meet the requirements of the operational resilience policies.

The resilience of market-based finance

The Bank’s development of new liquidity tools to support financial stability

42: The FPC received an update on the work the Bank has been doing to develop new tools for lending to NBFIs in the event of severe gilt market dysfunction that threatened UK financial stability. As part of its responsibilities under the Principles of Engagement governing the Bank’s balance sheet, the FPC approved the scope and principles determining the design of these new tools to ensure that they would be effective in ensuring the stability of the UK financial system:

The scope and principles determining the design of new tools for lending to NBFIs in the event of severe gilt market dysfunction

Scope

Purpose – to address severe gilt market dysfunction that threatens UK financial stability arising from shocks that temporarily increase non-banks’ market-wide demand for liquidity.

Circumstances for use – as a backstop in preference to asset purchases where lending is likely to be effective in tackling gilt market dysfunction and when the demand for liquidity is outside the reach of the Bank’s existing facilities to lend to banks.

Principles

Principle 1: Maintaining the incentive to build resilience and leaning against moral hazard – The tool needs to be designed such that it is consistent with the FPC’s broader approach to building non-bank resilience, and maintains incentives for firms to build their own resilience. The tool should act as a backstop, be designed in a way to minimise moral hazard, and not counteract efforts to increase private sector self-insurance.

Principle 2: Effectiveness in tackling gilt market dysfunction – The tool needs to be designed such that it can deliver its purpose of addressing severe gilt market dysfunction arising from shocks that temporarily increase non-banks’ demand for liquidity. It should do so by providing liquidity on terms such that: a) relevant eligible firms avoid undertaking forced gilt sales which can cause or amplify market dysfunction and b) the chance that asset purchases are needed is reduced.

43: As a first phase in this work, the Bank was putting in place a new Contingent NBFI Repo Facility (CNRF). The CNRF, which would be activated at the Bank’s discretionfootnote [1] during times of severe gilt market stress that threatened UK financial stability, would allow participating eligible pension funds, insurance companies and LDI funds to borrow cash against gilts at times of severe market dysfunction.footnote [2] The CNRF was expected to be open for eligible firms to sign up in 2024 Q4.

44: The FPC welcomed the progress the Bank had made in developing the CNRF. The Committee encouraged potential counterparties to familiarise themselves with the expected design and features of the CNRF and to assess what steps they would need to take in order to be ready to sign up to the facility when it opens for applications, to ensure that they would be operationally ready to use the facility if needed when it is activated during a market-wide stress. It is in the collective interests of all market participants that this new facility is effective at delivering liquidity to eligible counterparties when activated in order to restore UK financial stability.

45: The FPC would be kept updated on progress on the level of sign up to the facility as well as the Bank’s work to explore how to design a facility that could reach a broader set of NBFIs relevant to the functioning of core UK markets.

46: The FPC considered that resilience standards for MBF should be developed in coordination with work to enhance central bank tools to respond in stress. It was vital that domestic and international regulators continue to develop and implement policies that mitigate vulnerabilities in the system of MBF to ensure that it could absorb and not amplify severe but plausible shocks. As part of the Bank’s work to design a facility that could reach a broader set of NBFIs, it would engage closely with firms, industry bodies and regulators.

Policy work to address financial stability risks from margin requirements

47: The FPC had previouslyfootnote [3] highlighted the need for further policy work to address risks arising from procyclicality in margin requirements as part of addressing vulnerabilities in the NBFI sector. In cleared markets, NBFIs could struggle to predict initial margin calls during periods of market volatility and there could be added uncertainty about how clearing members would pass on these margin calls to their clients. Separately, in some bilateral markets such as government repo, very low or zero haircuts could allow NBFIs to take on excessive leverage. The bilateral and centrally cleared markets were interconnected, with investors in certain cases able to choose between the two. This interconnection leads to transmission of stress between the bilateral and cleared markets, and underscores the need for risk assessment and policy to consider them holistically. These dynamics were currently being explored through the Bank’s system-wide exploratory scenario exercise.

48: Proposals by the Basel Committee on Banking Supervision, the Bank for International Settlements’ Committee on Payments and Market Infrastructures and the International Organization of Securities Commissions that were consulted on earlier this year, seek to improve the transparency of initial margin calls in centrally cleared markets, and will require CCPs to further consider the potential procyclicality of margin calls by enhancing their evaluation of the responsiveness of initial margin models. The FPC supported this work to reduce potential risks arising from margin reactivity while ensuring robust management of counterparty credit risk in cleared markets, and looked forward to the proposals being finalised by relevant standard-setting bodies, incorporated into their respective policy frameworks and subsequently implemented by relevant authorities and industry.

49: Alongside greater transparency, the FPC supported other international work on margin, including the Financial Stability Board’s consultation on enhancing the liquidity preparedness of non-bank market participants to face spikes in margin and collateral calls. As these activities often involve taking on leverage, which can amplify liquidity stress, it was important that international work to identify and mitigate risks associated with non-bank leverage continues to progress.

Innovation in wholesale markets

50: The FPC and the Financial Markets Infrastructure Committee (FMIC) met jointly to discuss innovation in wholesale markets.

Wholesale uses of systemic stablecoins

51: In November 2023, the Bank published its proposed regulatory regime for systemic payment systems using stablecoins and related service providers, alongside a separate publication by the FCA proposing a regime for non-systemic stablecoins. The Bank’s proposed regime focused on sterling-denominated stablecoins that were intended to be used for retail purposes, and the Bank noted it would consider the risks and benefits of the use of stablecoins for wholesale purposes.

52: As such, the FPC discussed the implications of wholesale use of systemic stablecoins. The FPC noted that there were potential benefits of this. For example, stablecoins, like other forms of tokenised assets, could offer a reduction in settlement times, mitigating settlement risk and improving efficiency. They could also simplify the structure and chain of intermediaries within wholesale transactions and enable further automation, offering new functionalities and efficiencies.

53: The FPC had previously noted the importance of new forms of money respecting the principle of ‘singleness of money’, whereby all different forms of money must be exchangeable with each other at par value at all times. Even if stablecoins were backed with central bank deposits, there remained risks to the stability of the value of the stablecoin, for example as a result of operational risks or an imbalance between the supply and the demand for stablecoins, including if financial market participants run to this new low-risk asset at times of stress. If the value of stablecoins were to deviate from par, this would compromise their acceptance as a settlement asset and could have broader consequences for trust in money. These risks were particularly acute in wholesale markets given their systemic nature and could have financial stability implications.

54: The FPC noted that further technological solutions, business and risk management practices or regulation might mitigate these financial stability risks in future. The FPC supported their exploration given the potential benefits of wholesale use of stablecoins. More broadly, the FPC had a low risk appetite for a significant shift away from central bank money as the primary settlement asset in the financial system, given its role as a vital anchor for confidence. The FPC supported exploring how the benefits of innovation in money and payments could be harnessed, including central bank money alternatives that were compatible with distributed ledger technology, like improvements to central bank provided infrastructure or wholesale central bank digital currency technology.

Wholesale uses of tokenised funds

55: The FPC was briefed on potential uses of tokenisation, including for money market funds (MMFs) and the impact this could have on how MMF shares are managed and utilised.

56: Fund tokenisation activity was already emerging and there were potential efficiency gains and cost reduction from using new technology to administer fund shares. It also had the potential to affect what was used as collateral in the financial system. The FPC discussed the potential benefits and risks of using tokenised MMF shares as collateral in uncleared transactions. For example, it could reduce some liquidity mismatch risks in stress events by reducing the need for investors to redeem their MMF shares for cash to meet short-term liquidity needs—such as margin calls—where market participants could transfer tokenised MMF shares instead. But this activity could also create new risks particularly in more severe stress events where funds need to suspend redemptions, or where confidence was lost that the MMF unit could be redeemed at par.

57: The FPC noted that these benefits and risks could be explored further through the Bank/FCA Digital Securities Sandbox (DSS), and that this was consistent with the objective of the DSS, to experiment with new technologies and practices in traditional financial markets. Recognising that innovation in this area need not be limited to the DSS, the FPC would also monitor new and existing fund tokenisation activity taking place outside of the DSS.

Financial stability risks from artificial intelligence

58: In December 2023, the FPC agreed to further consider the financial stability risks from Artificial Intelligence (AI) and Machine Learning (ML) in 2024. The FPC therefore discussed the main channels through which AI could have financial stability implications, and the proposed approach to monitoring those risks.

59: The use of AI in the financial sector could deliver benefits, by driving greater operational efficiency, improving portfolio diversification and risk management, and providing new products and services. However, the adoption of AI could also introduce or amplify existing systemic risks. Both microprudential and macroprudential risks were seen as relevant to an assessment of the systemic risks from AI.

60: The FPC noted that uncertainty over the future evolution in the use and sophistication of AI systems, and how they are used in financial services and the broader economy, meant that the Committee’s assessment of systemic risks was likely to continue to evolve. The potential future impact of, and subsequent risks from, AI were also highly uncertain.

61: The Bank and FCA had taken steps to understand and address the microprudential risks from AI in regulated firms. This included a Discussion Paper and subsequent Feedback Statement on the implications of AI and ML for the prudential and conduct supervision of firms. In contrast, the macroprudential implications of AI had been less explored in regulatory work to-date.

62: Good firm-level risk management was the foundation of managing systemic risks from AI. Specifically, the most advanced AI models, including those based on Generative AI, could pose significant data (eg bias and privacy concerns), model risk (eg explainability), governance (eg predictability and incentive alignment) and risk management challenges. If the use of these advanced models became widespread, particularly in core financial applications, crystallisation of these risks could have systemic implications. As AI models become more powerful and autonomous, and as adoption increases, it would be important to ensure that regulatory frameworks that are neutral to different technologies are able to mitigate these risks sufficiently.

63: At the level of the financial system as a whole, macroprudential risks from AI could arise through structural vulnerabilities. Specifically, disruptions to or issues with common AI model technology and infrastructure systems (eg third party providers of services such as data or cloud infrastructure) might impact the AI models of many firms simultaneously.

64: Macroprudential risks could also arise because of externalities which have procyclical implications for financial markets, though the likelihood of these materialising was uncertain and debated. For example, common model dependencies could result in increasingly correlated trading strategies, and as AI-based trading algorithms become more sophisticated, they could adaptively learn and exploit the strategies of other participants in a manner which, whilst individually rational, could be destabilising for financial markets overall.

65: Systemic risks might also arise from the impact of AI outside the financial system, with second-order impacts on financial services (eg AI-enabled cyber attacks). The FPC noted the importance of the broader economy-wide context when considering the systemic risks from AI. The FPC received an update on broader AI policy context, including legislative developments in the UK and EU.

66: When considering next steps, the FPC supported the Bank, in collaboration with other regulatory bodies, taking actions to enable the effective monitoring of the systemic risks from AI. Developing an effective monitoring framework to understand the most material changes in the use and risks from AI was necessary in order to judge how well captured these risks were in existing regulatory approaches. The FPC also intended to clarify and set out the main systemic risk channels from AI, and planned to publish that assessment, and its proposed approach to monitoring those risks, in a Financial Stability in Focus report in the first half of 2025.

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The end of LIBOR | Bank of England

News release

Yesterday, 30 September 2024, the remaining synthetic LIBOR settings were published for the last time and LIBOR came to an end. All 35 LIBOR settings have now permanently ceased.  

The transition away from LIBOR, once referenced in an estimated $400 trillion of financial contracts, has made financial markets safer, more stable and fit for modern use. UK regulators, their international counterparts and market participants have worked together over the past decade to move to risk-free rates (“RFRs”), based on robust data.

Synthetic LIBOR was a temporary bridge to give firms more time to move outstanding legacy LIBOR-linked contracts towards alternative RFRs, allowing for an orderly cessation.

A milestone to celebrate

The transition from LIBOR has been a complex international cross-industry effort spanning well over a decade. The successful transition away from LIBOR would not have been possible without the work and contribution of many people across the globe, including market participants, trade bodies, regulators and other authorities.

Andrew Bailey, Governor of the Bank of England, said: “When I spoke about the future of LIBOR in 2017, this day seemed a long way off. However, market participants have worked tirelessly to update old contracts and support a smooth and effective transition to alternative risk-free reference rates. It has been exciting to follow the immense progress markets have made and I would like to express my thanks to all those involved. The financial stability risks from LIBOR in the UK have been effectively mitigated and allowed for an orderly cessation. It has been a long road, but markets are now operating on more robust and resilient foundations.” 

Nikhil Rathi, CEO of the Financial Conduct Authority, said: “The end of LIBOR is the epitome of a quiet regulatory success, of huge and complex risks unwound diligently over time, including during periods of unprecedented market turbulence. The transition away from LIBOR is one of the most significant events in markets in this generation. It was a task that at times seemed Herculean. Achieving it required coordination between public bodies, across borders and with industry. It shows what can be done through collaboration and with a shared goal. I want to thank everyone who made it happen.”

The Working Group has met its objective

Now LIBOR has been phased out, the Working Group has met its objective. Following agreement from its members, it will be wound down effective today 1 October 2024. 

The Bank and the FCA would like to thank all members of the Working Group, Sub-Group and Task Force members over the years for their valuable contributions in ensuring a successful transition away from LIBOR.

In particular, the Bank and FCA would like to thank the current chair, Sarah Boyce of The Association of Corporate Treasurers, and all former chairs for their support and guidance navigating the successful transition away from LIBOR.

Sarah Boyce, Chair of the Working Group on Sterling Risk-Free Reference Rates, said: “The Working Group has achieved its current objective of finalising the transition away from LIBOR, marking the end of its work. The successes of the Working Group would not have been possible without the efforts of its members and the effectiveness of the public-private partnership. I would like to thank all our members for helping us achieve an orderly transition from LIBOR to more robust reference rates.” 

Looking ahead

Market participants are encouraged to continue to ensure they use the most robust rates for the relevant currency, such as SONIA for GBP and SOFR for USD. Market participants should ensure their use of term risk-free reference rates, such as term SONIA and term SOFR are limited and remain consistent with the relevant guidance on best practice on the scope of use.

With the transition away from LIBOR completed, the Bank, the FCA and Working Group remind market participants that credit sensitive rates (“CSRs”) should not emerge as successor rates, supported by the FPC’s view that these rates are not robust or suitable for widespread use as a benchmark. In particular, the FCA and FPC have communicated to the market that USD CSRs have the potential to reintroduce many of the financial stability risks associated with LIBOR. 

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Minutes of the London FXJSC Operations Sub-committee Meeting – 19 June 2024

Minutes

Item 1 – Welcome and Apologies

James Kaye (Chair, HSBC) welcomed two new members to the Committee, Daniel Hoye (NatWest Markets) and Mark Codling (Deutsche Bank). The Chair also welcomed guests Adam Conn (Baillie Gifford), Andrew Harvey (Global Financial Markets Association), Lia Oyman (Franklin Templeton), Nigell Todd (Fidelity International) and Sarah Healey (Fidelity International). The Chair also welcomed alternates Aparna Shrivastava (Morgan Stanley), Dean Chard (SWIFT), and Emily Martin (Bank of England).

The Chair noted apologies from Andrew Batcher (LCH), Andrew Grice (Bank of England), Claire Forster-Lee (Morgan Stanley) and Joe Halberstadt (SWIFT).

Item 2 – Minutes of the February Meeting, feedback from the March Main FXJSC Committee meeting and Terms of Reference Review

The minutes from the 28 February 2024 meeting were agreed by Committee members.

The Chair provided an overview of the March Main Committee meetingfootnote [1] noting that there had been an update on the FX Global code review, and a discussion on the evolution of custody FX.

The Chair noted that the Terms of Reference (ToR) had been updated following the annual review. The updates were to include the monitoring of actual and emerging operational risks as a key aim of the Committee and to streamline the membership process. It was noted that the updated ToR would be circulated to members after the meeting for comment.

Item 3 – North American Transition to T+1 Securities Settlement

The Chair opened the discussion on the impact on FX markets of the North American transition to T+1 securities settlement, which had been implemented at the end of May 2024. The Chair noted that overall, feedback had been positive with no significant issues identified. This view was affirmed by guest attendees, noting that they had also seen limited impact from the migration.

Committee members noted that the success had partly been due to the high levels of preparation and coverage, including through increased operating hours. Although the Committee cited some caution as firms reverted to business-as-usual.

The impact of the migration to T+1 securities settlement would continue to be monitored.

Item 4 – Investment Association update

Alex Chow (Investment Association (IA)) noted that in addition to the North American transition to T+1 securities settlement, the IA had considered the challenges European Market Infrastructure Regulation (EMIR) reporting posed for buy-side firms. The IA had also established a focus group on FX netting. The IA were also partnering with the FIX Trading Community to promote the use of standardised reject codes.

Item 5 – CLS update 

John Hagon (CLS) noted that CLS ecosystem performance had improved markedly in the past 5-6 months.  

Preparations for the Alternative Processing Site (APS) were progressing at pace, and the APS was expected to be operationally ready in Q3 2024. A market-wide test of the APS would occur at the end of the year.

Regarding the June International Monetary Market (IMM) settlement day on 20 June, immediately following Juneteenth Day in the US, Mr Hagon noted that CLS were forecasting a settlement volume of 4 million sides and a settlement value of circa £19 trillion, adding that the projected volume was well within proven system capacity.   

Item 6 – GFXD update

Steve Forrest (UBS) provided an overview of the most recent GFMA FX Operations Committee meeting. There was a discussion on the North American move to T+1 securities settlement, and the April FX Settlement survey round. Mr Forrest further noted that the committee had also discussed the June IMM day, topics to cover in 2025, and agreed to establish a new resiliency-focused group.

Item 7 – FCA update

Oliver McCausland (FCA) noted that the FCA were in the pre-election quiet period. Essential business would continue but no major consultations or rule changes would be conducted during this period. It was also noted that the update to UK EMIR derivative reporting, known as EMIR Refit, would go-live in September 2024 and the FCA had published Q&As to support implementation.

Item 8 – FX Settlement Survey

Natalie Lovell (Bank of England) gave a brief overview of the April 2024 FX Settlement Survey. It was noted that the October 2024 survey round would provide a further opportunity for other central banks to adopt the new approach for collecting FX Settlement data ahead of the 2025 BIS Triennial survey.footnote [2]

Item 9 – Update on FX Settlement Crisis Playbook

Gail Smith (Deputy Chair – RBC Capital Markets) and Kerry Peacock (Deputy Chair – MUFG) gave an update on the FX Settlement Crisis Playbook. The playbook would be revised to be a best practice, principles-based document, and would include a non-exhaustive list of considerations for firms to consider in the event of an outage of a critical FX settlement system. A draft of the proposed playbook would be circulated to committee members for comment.

Item 10 – Any Other Business

The Chair noted that Paula Kenee (Northern Trust) would join the September meeting as an observer. It was noted that the September meeting would be hosted by Morgan Stanley at Canary Wharf.

Attendees

Aaron Mills – Citadel

Alex Chow – Investment Association

Anna Chadderton – Goldman Sachs

Daniel Hoye – NatWest Markets

Fiona O’Riordan – Citi

Gail Smith (Deputy Chair) – RBC Capital Markets

Gavin Platman – Insight Investment

James Andrews – JP Morgan

James Kaye (Chair) – HSBC

John Hagon – CLS

Kerry Peacock (Deputy Chair) – MUFG

Mark Codling – Deutsche Bank

Oliver McCausland – FCA

Steve Forrest – UBS

FXJSC Secretariat

Eleanor Garrett – Bank of England

Joe Hearn – Bank of England

Matthew Hartley (Legal Representative) – Bank of England

Natalie Lovell – Bank of England

Zish Jooma – Bank of England

Alternates

Aparna Shrivastava – Morgan Stanley

Dean Chard – SWIFT

Emily Martin – Bank of England

Guest attendees

Adam Conn – Baillie Gifford

Andrew Harvey – Global Financial Markets Association

Lia Oyman – Franklin Templeton

Nigell Todd – Fidelity International

Sarah Healy – Fidelity International

Apologies

Andrew Batchelor – LCH

Andrew Grice – Bank of England

Claire Forster-Lee – Morgan Stanley

Joe Halberstadt – SWIFT

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Minutes of the London FXJSC Main Committee Meeting – 25 June 2024

Minutes

Item 1 – Welcome and Apologies

Ms Saporta welcomed Adam Pickett (Citigroup), Jenny Wootton (Morgan Stanley), and Valentina Ziviani (Insight Investment) as guest presenters.

Ms Saporta welcomed Oliver McCausland (Financial Conduct Authority) and Lisa Danino-Lewis (CLS) as guest attendees; and Naresh Aggarwal (Association of Corporate Treasurers) and Chris Povey (CME) as observers.

Item 2 – March meeting Minutes

The minutes of the 6 March 2024 meeting were approved.

Item 3 – North America accelerated securities settlement cycle update

James Kaye (Chair of the FXJSC Operations Sub-Committee) noted that the Operations Sub-Committee had met on 19 June. The main agenda item had been a discussion on the impact on FX markets of the North American transition to T+1 securities settlement which had been implemented at the end of May 2024.

Mr Kaye noted that industry feedback on the transition had been positive with no significant issues identified. Firms had prepared for the transition in multiple ways, including through increased operating hours. The Committee cited some caution as firms reverted to business-as-usual following increased scrutiny during the transition period. Lisa Danino-Lewis (CLS) noted that there had not been an observable decrease in deals settling in CLSSettlement.

FXJSC members discussed that a transition to T+1 securities settlement in Europe would be more complicated than for the United States given Europe’s multiple markets and currencies.

Item 4 – Market Update

Giles Page and Adam Pickett (Citigroup) presented an update on recent market developments.

Mr Pickett outlined various factors driving FX markets. He noted that the macro picture remained relatively positive, driven by some robust global economic data.

Members discussed the potential impact of the various 2024 elections on the FX market and noted that the United States election would likely be the focus for H2 2024. Members noted that FX volatility broadly remained low in the near term, but some event volatility had been priced in to reflect election uncertainty. Members discussed that some of that uncertainty could persist beyond the elections as government policies unfolded.

Item 5 – Diversity, Equity, & Inclusion (DE&I) representatives meeting update

Jenny Wootton (Morgan Stanley) and Valentina Ziviani (Insight Investment) presented an update on a DE&I representatives’ meeting that took place on 15 May. The meeting was attended by twelve FXJSC member firms’ DE&I representatives across Human Resources and FX business units.

The presenters noted that the meeting was a welcome opportunity to discuss effective DE&I initiatives across firms, and the challenges that could arise.

Key themes that were highlighted during the discussion had included: the need for businesses to articulate a clear DE&I strategy; the importance of having DE&I representatives within FX business units; employees understanding the importance of firms collecting personal data to allow accurate benchmarking and to track progress; and the provision of training to middle management around inclusive leadership.

James Kemp (Financial Markets Standards Board) noted that the Global Foreign Exchange Division (GFXD) Next Step FX event had taken place on 6 June. The event had been aimed at diverse talent interested in exploring career opportunities within the FX market. The event had included a keynote speech from Sian Hurrell (Global Head, Sales & Relationship Management & Head of Global Markets Europe, RBC Capital Markets) and two panel sessions on the evolution and future of the FX market.

Item 6 – Global Foreign Exchange Committee (GFXC) Update and FX Settlement Survey Update

Simon Manwaring (NatWest Markets) gave a brief update on the GFXC’s FX Settlement Risk Working Group.

The Working Group was considering whether the FX Settlement Risk related areas of the FX Global Code (the “Code”) remained fit for purpose, as part of the three-year Code review. Mr Manwaring summarised the Working Group’s proposed changes to the Code, which included adding the risk waterfall approach for managing FX Settlement Risk to Principle 35. The proposed changes were due to be discussed at the Global FX Committee (GFXC) meeting on 1-2 July.

Philippe Lintern (Bank of England) gave a brief overview of the April 2024 FX Settlement Survey. It was noted that the October 2024 survey round would provide a further opportunity for other central banks to adopt the new approach for collecting FX Settlement data ahead of the 2025 BIS Triennial survey.footnote [1]

Item 7 – Market Structure Update – FX Futures & CME FX Link

Jeremy Smart (XTX Markets) and Paul Houston (CME) presented an overview of FX futures trends and the potential impacts on market structure.

Mr Houston outlined the increased participation in FX futures over the past 10 years, mostly driven by asset managers. Additionally, trading had become more established in CME FX Link, a Central Limit Order Book (CLOB) for trading spreads between spot and futures. Although fundamentally a different product to traditional over-the-counter (OTC) spot FX, the futures market had nevertheless become an important source of price discovery and FX risk management.

Mr Smart outlined the potential trade-offs and differences between the CME futures market and traditional FX trading venues. For some participants, the futures market offered an efficient and robust rules-based trading venue, but it was also more complex, traded fewer currency pairs, and many market participants did not have access to the market. At times, primary price formation occurred on CME across several currency pairs, yet in some episodes of market volatility, trading and price formation had resorted to OTC cash platforms.

Members discussed the evolving FX market structure landscape. There was a range of views on the effect of reduced levels of spot activity on OTC primary venues relative to that in the FX futures market. For some participants, the change in location of trading could make price discovery challenging, particularly in times of heightened volatility. To date, the diverse nature of the FX market had been resilient in recent periods of high volatility, and both banks and non-bank market-makers continued to play an important role in the intermediation and provision of liquidity across that fragmented marketplace.

The Committee would continue to monitor this topic and bring it back to a future FXJSC meeting if required.

Item 8 – FXJSC Sub-Committee updates

Sharon Blackman (Chair of the Legal Sub-Committee) noted that the Sub-Committee had met on 18 June. Agenda items had included: an update on Artificial Intelligence (AI) and Financial Services from Latham & Watkins, which provided an overview of UK AI regulation and a discussion on the global divergence in regulatory approaches; a view from Jonathan Ashley-Norman KC, Three Raymon Buildings Barristers on the Post-Office Inquiry; and a discussion on ethics in the legal profession.

Item 9 – Regular updates

James Kemp (FICC Markets Standards Board) noted that the Financial Markets Standards Board (FMSB) continued to draft the pre-hedging Spotlight Review. Based on the outcome of the drafting process, the goal was to release the review to inform the IOSCO consultation expected later in 2024.

Attendees

Galina Dimitrova – The Investment Association

Giles Page – Citigroup

James Kaye (Chair, FXJSC Operations Sub-committee) – HSBC

James Kemp – FICC Markets Standards Board

Jeremy Smart – XTX Markets

Kate Hill – Aviva Investors

Kevin Kimmel – Citadel Securities

Lisa Dukes – Corporate Representative – Association of Corporate Treasurers

Mani Natarajan – Morgan Stanley

Neehal Shah – BNP Paribas

Nina Moylett – M&G plc

Paul Houston – CME Group

Philippe Lintern – Bank of England

Rajesh Venkataramani – Goldman Sachs

Richard Purssell – Insight Investment

Sally Francis-Cole – London Stock Exchange Group

Sarah Boyce – Association of Corporate Treasurers

Sarah Collins – UBS Asset Management

Sharon Blackman (Chair, FXJSC Legal Sub-committee) – Citigroup

Simon Manwaring – NatWest Markets

Sophie Rutherford – State Street

Stephen Jefferies – JP Morgan

Vicky Saporta (Chair) – Bank of England

FXJSC Secretariat

James O’Connor – Bank of England

Joseph Hanrahan – Bank of England

Laura Austin – Bank of England

Sakshi Gupta (Legal Secretariat) – Bank of England

Guest attendees

Adam Pickett – Citigroup

Chris Povey – CME

Jenny Wootton – Morgan Stanley

Lisa Danino-Lewis – CLS

Naresh Aggarwal – Association of Corporate Treasurers

Oliver McCausland – Financial Conduct Authority

Valentina Ziviani – Insight Investment

Apologies

Alan Barnes – Financial Conduct Authority

Marc Bayle de Jesse – CLS

Mimi Rushton – Barclays

Richard Bibbey – HSBC

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Minutes of the London FXJSC Legal Sub-committee Meeting – 18 June 2024

Minutes

Minute 1: Introduction

The Chair (Sharon Blackman) opened the meeting.

Minute 2: Minutes

The minutes of the meeting of 5 March 2024 were approved.

Minute 3: AI and Financial Services update from Latham & Watkins (Becky Critchley & Gabriel Lakeman)

The speakers presented on the following five areas within AI.

Overview of AI regulation in the UK

There is no single overarching legislative framework or single regulatory function to govern AI. Instead, there is a non-statutory, principles-based approach to be implemented by sector-specific regulators.

There are a variety of examples of the rules and legislation that already apply to the use of AI in a financial services context, including:

  • Consumer Duty: The Financial Conduct Authority’s Consumer Duty imposes broad “crosscutting” obligations on firms, including the requirement to “act to deliver good outcomes for retail customers”. The key issue is how to ensure use of AI is compliant with the Consumer Duty, including ability to foresee harm
  • Outsourcing/Third-party risk management (“TPRM”): Firms are subject to a detailed regime when outsourcing critical or important functions, but the key issue is the extent to which the use of AI involves outsourcing/ reliance on third-party providers, and has been assessed against the firm’s outsourcing policies and procedures.
  • Senior Manager & Conduct Rules (“SM&CR”): SM&CR aims to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence. The key issue is who should ultimately be responsible for AI, including under the SM&CR.

Developments in AI use

The speakers noted that they are being asked increasingly about AI assistance, although they haven’t yet had clients ask for them to use co-pilot in meetings. The speakers outlined recent examples where AI is being used and in what context, highlighting that this is an area to watch.

Key risk considerations

There are a variety of emerging AI risks, some were highlighted:

  • Making unsupported recommendations
  • Lack of human oversight/interaction
  • Conflicts of interests
  • Completely false information (hallucinations)
  • Bias and discrimination
  • Inadvertent performance of regulated activities
  • Data privacy and security
  • Market stability

There are Risk Mitigation Strategies that can be adopted by firms, to ensure alignment with the current regulatory obligations:

  • Firms can understand how legal and regulatory obligations interact with AI use, and ensure that they are able to explain their use of AI to regulators.
  • Carry out risk assessments and assign risk ratings
  • Consider and account for data protection considerations
  • Consider governance arrangements and that a robust AI governance framework is in place
  • Consider the existing systems and controls and policy framework and whether any enhancements should be made

The Global FX Code and AI principles

The speakers explained that there six leading principles under the Code which are relevant in the context of AI and under which the use of AI can be considered in an FX context:

  • Ethics: Market Participants are expected to behave in an ethical and professional manner to promote the fairness and integrity of the FX Market.
  • Governance: Market Participants are expected to have a sound and effective governance framework to provide for clear responsibility for and comprehensive oversight of their FX Market activity and to promote responsible engagement in the FX Market.
  • Execution: Market Participants are expected to exercise care when negotiating and executing transactions in order to promote a robust, fair, open, liquid, and appropriately transparent FX Market.
  • Information Sharing: Market Participants are expected to be clear and accurate in their communications and to protect confidential information to promote effective communication that supports a robust, fair, open, liquid, and appropriately transparent FX Market.
  • Risk Management and Compliance: Market Participants are expected to promote and maintain a robust control and compliance environment to effectively identify, manage, and report on the risks associated with their engagement in the FX Market.
  • Confirmation and Settlement Processes: Market Participants are expected to put in place robust, efficient, transparent, and risk-mitigating post-trade processes to promote the predictable, smooth, and timely settlement of transactions in the FX Market.

Emerging ethical issues

There are emerging ethical issues that firms are grappling with when developing and utilising AI. Comparisons were drawn between approaches in the EU, UK and other jurisdictions. The speakers noted that the EU approach is quite interesting as they have come in with a legislative regime very early on.

The use of AI in the supply chain was discussed with the participants asking how far they should go to ensure that their suppliers are managing AI. The speakers noted that this is a question that could be asked of suppliers so that they declare what AI they are using, and firms can consider this in their AI risk management frameworks.

Minute 4: The Post Office Inquiry and ethics in the legal profession (Jonathan Ashley-Norman KC, Three Raymond Buildings Barristers)

Mr Ashley-Norman started by giving an historical overview of the events that led to the Health & Safety at Work Act (“HSAW”) 1974, which was developed in response to the particularly dangerous employment conditions that existed the UK at that time. He explained that, amongst other things, the HSAW 1974 made it a criminal offence for an employer to conduct its undertaking in such a way that it fails to ensure the safety of its employees. This created an extremely wide duty on the boards of companies, specifically the individual responsible for health & safety. As risk assessment regimes and codes of practice have been finessed over the years, there has been a corresponding decrease of deaths in the health & safety context. The HSAW 1974 has in large measure completed its task by instilling in the board room the matters relating to health & safety.

Other legislation can be looked at as doing effectively the same thing in instilling boardroom responsibility in other areas, by acting as the deterrent and changing corporate behaviour, e.g., Proceeds of Crime Act 2002, Bribery Act 2010 and Economic Crime Act 2023.

In relation to the Post Office, it will have had managers and directors subject to such obligations, various issues were brought to their attention, and yet they seemingly failed in their duty of care, and so will potentially be at the wrong end of criminal investigation.

Mr Ashley-Norman then put this into the context of the Global FX Code, which is organised around six leading principles: Ethics, Governance, Execution, Information Sharing, Risk Management and Compliance and Confirmation and Settlement Processes. The history of dishonesty, the Ghosh test, which is an objective test, was discussed alongside the Ivey test.

It was noted that an organisation’s culture is hard to change and influence.

Minute 5: Any other business

There was no other business discussed.

Attendees

Sharon Blackman (Chair) – Citigroup
Baljit Saini – NatWest (virtual)
David Harris – Financial Conduct Authority (virtual)
Rakesh Shah – Standard Chartered (virtual)
Rowland Stacey – Goldman Sachs
Simon Goldsworthy – Deutsche Bank (virtual)
Tamsin Rolls – JP Morgan Chase

FXJSC Legal Sub-Committee Secretariat

Sakshi Gupta – Bank of England
Matthew Hartley – Bank of England
Carly Jones – Bank of England

Guest attendees

Becky Critchley – Latham & Watkins
Gabriel Lakeman – Latham & Watkins
Charlotte Branfield – Three Raymond Buildings Barristers
Jonathan Ashley-Norman KC – Three Raymond Buildings Barristers

Apologies

Gaynor Wood – CLS
Harkamal Singh Atwal – HSBC
Krisha Somaiya – UBS
Mayank Patel – Bank of America
Nimisha Kanabar – Morgan Stanley
Sunil Samani – XTX Markets

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FCA and PRA appoint new Chair of the FSCS

The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) have appointed Elizabeth Passey as Chair of the Financial Services Compensation Scheme’s (FSCS) board. She will take up the role on 1 October 2024.

Over a 30-year career, Elizabeth held senior positions with J Stern & Company, Investec Asset Management and Morgan Stanley. She recently completed 2 terms as Chair of the Rural Payments Agency, and as convener of the University of Glasgow.

The appointment was made by the FCA Board and the Prudential Regulation Committee (PRC) with the approval of HM Treasury. Elizabeth Passey succeeds Marshall Bailey OBE, who is stepping down after 2 terms as FSCS Chair.

The FCA’s senior independent director, Richard Lloyd OBE, who was on the selection panel commented:

“Elizabeth will bring a wealth of experience of financial services, public service and governance to the role and we look forward to working with her.

“I want to thank Marshall for his impressive leadership over the last 6 years, a period of significant change for the FSCS.”

Commenting on her appointment, Elizabeth Passey, said:

“I am delighted to be joining the FSCS as its new Chair. The FSCS provides trust in financial services, and this is arguably more important than ever. It is vital the organisation continues to provide a high-quality service that gives consumers the confidence to save and invest.

“Marshall and the FSCS’ board have directed the organisation through a significant change to its work, with a steep rise in complex claims over the last 6 years. I’m looking forward to working with the other directors and the executive team to help the FSCS continue its evolution as a compensation scheme, so that it can best protect consumers in the years ahead.”

Notes to editors

  1. The FCA and the PRA are required by the Financial Services and Markets Act 2000 (FSMA) to appoint the Chair of the FSCS, with the appointment being approved by HM Treasury. The appointment must be on terms that secure appointees’ independence from the FCA and the PRA in the operation of the compensation scheme.
  2. The Board of the FSCS is responsible for ensuring that the compensation scheme is properly resourced and able to carry out its work effectively and independently.
  3. Elizabeth Passey is currently a senior adviser at J Stern & Company, a member of the investment committee of the Goldsmiths Company, a member of the boards of the Rivers Trust and the Wye & Usk Foundation, a patron of Clean-up UK and ambassador for the 30% Club. Elizabeth previously provided consultancy services to Artemis Investment Management between 2018 and 2019 and EFG Harris Allday in 2018. Prior to this she was a managing director for Investec Asset Management between 2012 to 2014 and for Morgan Stanley between 2006 to 2012, having held various senior roles since starting at Morgan Stanley in 1994. She recently completed tenures as Chair of the Rural Payments Agency (2018 to 2024) and the University of Glasgow (2016 to 2024). She was a board member of VPC Specialty Lending Investments PLC from 2015 to 2023 and a UK board member of The National Lottery Community Fund from 2014 to 2022.
  4. The FSCS was set up as a statutory compensation scheme for customers of FCA and PRA UK-authorised financial services firms that are unable, or likely to be unable to meet claims made against them. It can help with most financial products – including deposits, insurance, PPI, debt management, funeral plans, mortgages, pensions and investments.
  5. Find out more information about the FSCS.
  6. Find out more information about the FCA.
  7. Find out more information about the PRA.

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Minutes of the UK Money Markets Code Sub-Committee – July 2024

Minutes

Item 1: Introduction

Nic Erevik (NE) welcomed Committee members to this hybrid meeting, the first UK Money Market Code Sub-Committee (the Committee) meeting of 2024.

Committee members were formally informed that Niv Erevik has replaced Terry Barton as Co-Chair of the Committee.

NE (on behalf of the Committee) thanked Terry Barton for his contribution to the Committee’s work over the years, including during his tenure as co-chair, and to the review of the UK Money Market Code last year. The Committee wishes him well for the future.

Item 2: Minutes of last meeting

The minutes of the last meeting were published on the Bank’s website.

Item 3: Terms of Reference for the UK Money Market Code Sub-Committee

The Committee ratified the updated Terms of Reference (ToR) of the Committee.

Item 4: Promoting the updated UK Money Market Code/ACT Conference – Readout on the session on Codes

The latest update of the UK Money Market Code (the Code) was published on 7 June 2024. Feedback from the market indicated that the updated Code had been well-received. The Committee agreed, however, that there was scope for further promoting the Code among market participants. The Committee discussed various channels to explore, including using trade associations to increase its visibility and promote the benefits of signing up to the Code (for example, via websites and industry events).

The Association of Corporate Treasurers (ACT) held their annual meeting in May 2024 at which there was a dedicated panel session on Codes of Conduct. This session covered the UK Money Market Code, Global FX Code as well as the standards of the Financial Markets Standards Board with the aim of educating on: (i) the purpose of voluntary codes; (ii) their importance and the benefits to corporate entities; (iii) obligations for firms and (iv) latest developments. A member of Bank staff was invited to speak on the Money Market Code. A summary was published in the Treasurers’ Magazine and a one-pager on the Code linked to the ACT newsletter. It was noted that many attendees were unaware of the Code. The Committee discussed possible actions to increase awareness among non-financial institutions with the aim increasing corporate signatories.

Item 5: Update: Working Groups on Settlement Efficiency (Securities Lending Committee & LMMA)

The work of the London Money Market Association’s (LMMA) working group on settlement efficiency continues. The Committee will continue to be kept informed as it progresses.

The Committee was informed that there has been a significant improvement in settlement efficiencies in the cleared repo space over the last eighteen months. This improvement has largely been due to the increased uptake of CREST’s auto-splitting facility.

The Securities Lending Committee’s Working Group’s (the Working Group) report on Settlement Efficiency was published on the Bank’s website on 17 June 2024. The report was well received and discussed at the International Securities Lending Association (ISLA) conference in June 2024. The Working Group is now embarking on the second phase of its work and will provide a bulletin in the autumn, commenting on lessons learnt from T+1 in North America. Here the working group will also collate updates and information from electronic platform vendors, market participants, the UK’s T+1 task force, trade associations and industry bodies. There will also be discussions with Central Clearing Counterparties (CCPs) providing securities lending clearing solutions. The Working Group will continue its work with CREST to provide a comprehensive overview of securities lending settlement dates and use this in conjunction with other industry data providers.  This will allow the Working Group to provide data to support the initial research and allow monitoring of the securities lending market on an ongoing basis.

Item 6: Diversity and Inclusion (DE&I)

Representatives of three trade associations (members of the Committee) spoke about some of the D&I initiatives being carried out by their respective trade associations. These initiatives focussed on inclusivity via getting younger/junior staff of their respective members to meet up with senior staff. One trade association offered individuals at the beginning of their careers and career returners, discounted tickets to their events. Thus, providing these staff with opportunities they wouldn’t typically get. Another initiative involved providing a series of education-based sessions to the aforementioned groups on topic such as: (i) the Basel Framework; (ii) the data the ISLA uses to think about the Securities Lending market, (iii) the work of the UK Debt Management Office and (iv) a talk on the City of London. Further education-based sessions are being planned for later in the year.

A meeting between banks and the largest Corporate Treasurers in London (one of the initiatives discussed) culminated in the inaugural Diversity and Sustainability Awards 2024 which takes place in London on 16 October and for which the short-list of nominees for the awards have been published.

One member also spoke about a joint meeting their trade association had held with another trade association to promote diversity and inclusion.

The Committee welcome these initiatives and agreed that holding joint DE&I events between associations is a good idea for promoting DE&I within money markets.

Item 7: AOB

No AOB.

Committee attendees

Attendees (in-person)

Alessandro Cozzani – BofA
Helen Willingale – Blackrock
Ina Budh-Raja (Co-Chair) – BNY Mellon
Jack Skinner – DMO (Observer)
James McKerrow – Insight Investment
Ian Mair – LMMA
Philip Chilvers – TP ICAP

Attendees (Virtual)

Gordon Lowson – Aberdeen Standard Investments
James Winterton – Association of Corporate Treasurers
John Edwards – CME Group
Vicky Worsfold – Surrey Heath Borough Council
Andy Dyson – ISLA
Veronica Iommi – IMMFA
James Upton – LCH
Andrew Welch – LGIM
Nic Erevik (Co-Chair) – Newcastle Building Society

Bank of England

Simon Dolan
Tom Archer
Kpakpo Brown

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Bank Rate maintained at 5% – September 2024

Monetary Policy Summary, September 2024

The Monetary Policy Committee (MPC) sets monetary policy to meet the 2% inflation target, and in a way that helps to sustain growth and employment. The MPC adopts a medium-term and forward-looking approach to determine the monetary stance required to achieve the inflation target sustainably.

At its meeting ending on 18 September 2024, the MPC voted by a majority of 8–1 to maintain Bank Rate at 5%. One member preferred to reduce Bank Rate by 0.25 percentage points, to 4.75%. The Committee voted unanimously to reduce the stock of UK government bond purchases held for monetary policy purposes, and financed by the issuance of central bank reserves, by £100 billion over the next 12 months, to a total of £558 billion.

Monetary policy decisions have been guided by the need to squeeze persistent inflationary pressures out of the system so as to return CPI inflation to the 2% target both in a timely manner and on a lasting basis. Policy has been acting to ensure that inflation expectations remain well anchored. As set out at the time of the August Monetary Policy Report, the Committee’s deliberations have been supported by the consideration of a range of cases, to which different probabilities and different risks can be attached.

In the first case, the unwinding of the global shocks that drove up inflation and the resulting fall in headline inflation should continue to feed through to weaker pay and price-setting dynamics. The persistence of inflationary pressures would therefore dissipate with a less restrictive stance of monetary policy than in other cases.

In the second case, a period of economic slack, in which GDP falls below potential and the labour market eases further, may be required in order for pay and price-setting dynamics to normalise fully. Domestic inflationary persistence would then be expected to fade away, owing to the opening up of slack from a more restrictive stance of monetary policy relative to the first case.

In the third case, the economy may be subject to structural shifts such as changes in wage and price-setting following the major supply shocks experienced over recent years. The degree of restrictiveness of monetary policy may be less than embodied in the Committee’s latest assessment, meaning that monetary policy would have to remain tighter for longer.

Since the MPC’s previous meeting, global activity growth has continued at a steady pace, although some data outturns suggest greater uncertainty around the near-term outlook. Oil prices have fallen back, reflecting in large part weaker demand. Market-implied paths for policy rates across major advanced economies have declined.

There has generally been limited news in UK economic indicators relative to the Committee’s expectations in the August Monetary Policy Report. Headline GDP growth is expected to return to its underlying pace of around 0.3% per quarter in the second half of the year. Twelve-month CPI inflation was 2.2% in August, and is expected to increase to around 2½% towards the end of this year as declines in energy prices last year fall out of the annual comparison. Services consumer price inflation remained elevated at 5.6% in August. Private sector regular average weekly earnings growth declined to 4.9% in the three months to July.

At this meeting, the Committee voted to maintain Bank Rate at 5%.

In the absence of material developments, a gradual approach to removing policy restraint remains appropriate. Monetary policy will need to continue to remain restrictive for sufficiently long until the risks to inflation returning sustainably to the 2% target in the medium term have dissipated further. The Committee continues to monitor closely the risks of inflation persistence and will decide the appropriate degree of monetary policy restrictiveness at each meeting.

Minutes of the Monetary Policy Committee meeting ending on 18 September 2024

1: Before turning to its immediate policy decisions, the Committee discussed: the international economy; monetary and financial conditions; demand and output; and supply, costs and prices.

The international economy

1: UK-weighted global GDP was estimated to have grown by 0.5% in 2024 Q2, broadly in line with the projection in the August Monetary Policy Report, and consistent with steady growth over recent quarters. US GDP had grown more strongly than had been anticipated, while GDP growth had moderated in the euro area and in China in the second quarter.

2: In the third quarter, euro-area GDP growth was expected to be a little weaker than had been anticipated in the August Report, and US GDP growth was expected to moderate somewhat, in line with previous expectations. Activity indicators such as PMIs suggested ongoing weakness in the manufacturing sector in both economies over recent months, while the services sector had continued to expand.

3: Labour market outturns in the United States had been softer in July and August relative to previous months. Unemployment in the euro area had remained low, pointing to some continuing tightness. Wage growth had continued to moderate across both regions.

4: Headline consumer price inflation had declined further towards central bank targets in the euro area and in the United States. In the euro area, 12-month HICP inflation had been 2.2% in August, while core inflation had ticked down to 2.8%, in line with market participants’ expectations. US CPI inflation had fallen to 2.5% in August, while core CPI inflation had remained unchanged at 3.2%, also in line with market expectations. Annual services price inflation had remained elevated in both economies, although higher frequency measures pointed to some easing over recent months.

5: There were tentative signs of a shift in the balance of risks to global activity towards the downside. Consistent with that, since the MPC’s previous meeting, the Brent spot oil price had declined by around 6%, to $75 per barrel. Market contacts had ascribed the moves largely to weaker demand in China, as indicators of domestic demand there had continued to be soft.

Monetary and financial conditions

6: Since the MPC’s previous meeting, government bond yields had fallen across major advanced economies in response to the softening in US labour market data and associated FOMC communications. Market-implied paths for policy rates across economies had generally ended the period lower. Coupled with UK data releases in that period having been largely in line with market expectations, that meant UK interest rate movements had been driven primarily by developments in the United States. Nevertheless, the UK market-implied path had fallen by less than in the United States. That had been associated with an appreciation of sterling against the dollar of 3%, which had accounted for most of the 1% increase in the sterling effective exchange rate since the previous MPC meeting.

7: Movements in yields across major advanced economies had been particularly pronounced early in August, alongside large moves in asset prices more generally. Market-specific factors including seasonally low market liquidity were likely to have exacerbated reactions to news. While these early August moves had unwound quickly, yields across countries had nevertheless ended the period lower. In contrast, UK equity prices had been little changed since the MPC’s previous meeting and the S&P 500 and Euro Stoxx 50 had both increased somewhat.

8: At its meeting on 12 September, the ECB Governing Council had reduced its key policy rate by 25 basis points, in line with market expectations. In its statement, the Governing Council had reiterated its data-dependent and meeting-by-meeting approach, focused on the inflation outlook and strength of policy transmission. At its meeting ending on 18 September, the FOMC was expected to reduce the federal funds rate by either 25 or 50 basis points.

9: In the United Kingdom, Bank Rate expectations implied by market pricing had continued to suggest that the next 25 basis point cut would occur in November. That was consistent with the Bank’s latest Market Participants Survey (MaPS). Beyond November, while the median MaPS profile implied a slightly slower pace of reduction in Bank Rate than the market-implied path, both pointed to much more gradual reductions than were expected in the United States and to a lesser extent in the euro area.

10: Regarding credit conditions, it was too soon to assess fully the extent to which the Bank Rate reduction in August had passed through to the relevant saving and borrowing rates facing households and corporates. Nevertheless, as had been anticipated, mortgage rates had fallen since the MPC’s previous meeting broadly in line with declines in risk-free reference rates.

11: The share of two-year fixed-rate mortgages within new secured household lending had been increasing since 2023 Q1, despite rates on these mortgages being above five-year fixed rates over this period. That had reversed the previous trend whereby longer-duration mortgage fixes had increased in popularity since 2016, probably reflecting household expectations of lower interest rates. Slow mortgage stock turnover meant that the share of five-year fixed-rate mortgages in outstanding lending had remained historically high.

12: Household saving preferences had also adjusted over the past year, as rates offered on time deposits had become relatively less attractive, reflecting the declines in risk-free reference rates. Deposit flows had shifted into sight deposits and ISAs, many of which were instant access. Household deposits had continued to be the main driver of aggregate sterling broad money growth. The latter had increased to 1.6% on an annual basis in July, but had remained weak by historical standards.

Demand and output

13: UK GDP had increased by 0.6% in 2024 Q2, 0.1 percentage points lower than had been expected in the August Monetary Policy Report. That had followed 0.7% growth in Q1, but Bank staff judged that the underlying pace of growth had been somewhat weaker during the first half of the year.

14: Within the expenditure components of Q2 GDP, household consumption had risen by 0.2% on the quarter, while business and housing investment had both declined by 0.1%. Real government expenditure had increased by 1.6%, and there had continued to be some evidence of greater-than-projected central government spending in recent public sector finances data.

15: GDP had been unchanged on the month in both July and June but had grown by 0.5% on a three-month-on-three-month basis in July. Slightly weaker-than-expected output in July had been concentrated in the manufacturing and professional services sectors.

16: Bank staff now expected GDP growth of 0.3% in 2024 Q3, marginally weaker than the 0.4% rate that had been incorporated in the August Report. That was broadly in line with estimates of the underlying growth rate that had been extracted from models based on a range of business survey indicators and on disaggregated GDP data. The latest intelligence from the Bank’s Agents suggested that improving real incomes, the August Bank Rate reduction and anticipated further cuts in interest rates had underpinned improved sentiment and expectations of increased activity across most sectors around the turn of the year.

17: There had been little news from most indicators of consumer spending, although housing market data had strengthened somewhat. Retail sales volumes had been volatile, around a very gradually rising trend since the start of the year. GfK consumer confidence had been unchanged in August. Forward-looking indicators in the housing market had continued to point to a recovery in home buyer enquiries and prices, while mortgage approvals for house purchase had increased to their highest level since September 2022.

18: The Committee discussed the near-term outlook for activity and the evolution of the output gap. Although uncertainties surrounded this assessment, overall demand and supply were judged to have been broadly in balance over recent quarters. A continuation of the current pace of underlying GDP growth would, given the Committee’s view of potential supply growth, be consistent with little change in the output gap through the end of this year. That path was a little stronger than the August Report projections, however, in which demand growth had been expected to slow at the end of this year and a significant margin of spare capacity had been projected to open up over time. That projection in part reflected the previously announced medium-term tightening in the stance of fiscal policy, prior to the upcoming Budget. The Committee would also continue to monitor closely how the different channels of the monetary transmission mechanism were interacting with the dynamics of the household saving ratio, and in turn the outlook for consumer demand.

Supply, costs and prices

19: Labour market data quality issues continued to be an area of concern. Very low achieved sample sizes meant Labour Force Survey (LFS)-based estimates of labour market dynamics remained subject to considerable uncertainties. This was making it difficult to gauge the underlying state of labour market activity. The MPC had, for some time, utilised a wide range of data to inform its judgements on the labour market, including official data, business surveys and intelligence from the Bank’s Agents.

20: A Bank staff indicator model of underlying employment continued to point to growth of around 0.2% per quarter, broadly in line with population growth. There was greater dispersion among outturns from individual employment indicators. The KPMG/REC/S&P Global UK Report on Jobs had continued to point to a contraction in employment while the Lloyds Business Barometer suggested an expansion.

21: In line with softening labour demand, vacancies had continued to fall back gradually, although at a slower pace than in 2023 and they had remained above pre-pandemic levels. The REC Report and Agents’ intelligence signalled a continued easing in recruitment difficulties, with the latter suggesting improved job retention in some sectors. The vacancies-to-unemployment ratio had returned to its pre-pandemic average at the start of 2024 Q2. A Bank staff indicator model suggested that underlying unemployment had increased steadily over the past few quarters, in contrast to more volatile LFS data.

22: Indicators of households’ inflation expectations had largely normalised to close to their historical averages. The Bank of England/Ipsos Inflation Attitudes Survey’s measure of median short-term inflation expectations had fallen to 2.7% in August. The corresponding measure of medium-term expectations had remained close to, but below, its historical average. The Citi/YouGov indicator of households’ short-term inflation expectations had increased slightly to 3.1% in August from 2.7% previously, possibly owing to media reports of a rise in the Ofgem utility price cap in October. Businesses’ own price expectations, as reported in the DMP Survey, had remained at slightly more elevated levels, although on a continued downward path.

23: This normalisation in inflation expectations, as well as, to a lesser extent, the easing in labour market tightness, had supported continued moderation in pay growth. Annual private sector regular average weekly earnings growth had eased to 4.9% in the three months to July from 5.3% in the three months to June, broadly in line with August Monetary Policy Report projections. Other surveys suggested that wage growth would continue to moderate, although remain above inflation target-consistent levels, with the DMP Survey indicating a fall to approximately 4% over the next year. The latest Agents’ intelligence indicated that pay settlements over the second half of the year were, as expected, coming in at lower rates compared to H1, and 2025-expected settlements might be in a 2 to 4% range. There remained the possibility of some upside risk to pay growth depending on the trajectory of the National Living Wage (NLW) in the first half of next year.

24: Twelve-month CPI inflation had been 2.2% in August and July, slightly lower than August Report expectations. Consumer core goods and food price inflation had remained subdued as the cost pressures from previous global shocks had unwound further, and producer price levels had been broadly flat. Energy prices had continued to drag on CPI inflation.

25: Services price inflation had increased to 5.6% in August compared to 5.2% in July and 5.7% in June. This was slightly lower in August than had been expected at the time of the August Report. There had been volatility in a number of services sub-components in the July and August outturns, including accommodation and catering prices and airfares.

26: The Committee discussed momentum in services price inflation and price-setting behaviour in firms. Strength in services price inflation was supported by evidence from the DMP Survey which showed firms’ own-price inflation continuing to fall, but to a lesser extent among services firms. July CPI microdata pointed to a higher proportion of services prices being raised each month than was the case pre-Covid, though with some easing in catering services where food input costs had moderated. The monthly annualised inflation rates of a seasonally adjusted services price measure, which excluded indexed and volatile components, rents and foreign holidays, had averaged around 4% in the three months to August, close to its average since the end of 2023. Although it had fallen from its peak level, the apparent stability in this measure suggested further pass-through from lower labour costs and easing inflation expectations was still to come. Accordingly, Bank staff expected services inflation to ease slightly further in Q4.

27: CPI inflation was expected to increase somewhat over the remainder of this year, owing to the smaller drag on 12-month inflation from domestic energy bills. The announced uptick in utility prices to take effect in October was likely to be offset somewhat by the recent decrease in petrol prices.

The immediate policy decisions

28: The Monetary Policy Committee sets monetary policy to meet the 2% inflation target, and in a way that helps to sustain growth and employment. The MPC adopts a medium-term and forward-looking approach to determine the monetary stance required to achieve the inflation target sustainably.

29: Monetary policy decisions had been guided by the need to squeeze persistent inflationary pressures out of the system so as to return CPI inflation to the 2% target both in a timely manner and on a lasting basis. Policy had been acting to ensure that inflation expectations remained well anchored. As set out at the time of the August Monetary Policy Report, the Committee’s deliberations had been supported by the consideration of a range of cases, to which different probabilities and different risks could be attached.

30: In the first case, the unwinding of the global shocks that had driven up inflation and the resulting fall in headline inflation should continue to feed through to weaker pay and price-setting dynamics. The persistence of inflationary pressures would therefore dissipate with a less restrictive stance of monetary policy than in other cases.

31: In the second case, a period of economic slack, in which GDP fell below potential and the labour market eased further, might be required in order for pay and price-setting dynamics to normalise fully. Domestic inflationary persistence would then be expected to fade away, owing to the opening up of slack from a more restrictive stance of monetary policy relative to the first case.

32: In the third case, the economy might be subject to structural shifts such as changes in wage and price-setting following the major supply shocks that had been experienced over recent years. The degree of restrictiveness of monetary policy might be less than embodied in the Committee’s latest assessment, meaning that monetary policy would have to remain tighter for longer.

33: The Committee continued to monitor the accumulation of evidence from a broad range of indicators, with a focus on the extent to which it was possible over time to use developments in data series to assess the various cases.

34: Since the MPC’s previous meeting, global activity growth had continued at a steady pace, although some data outturns suggested greater uncertainty around the near-term outlook. Oil prices had fallen back, reflecting in large part weaker demand. Market-implied paths for policy rates across major advanced economies had declined.

35: There had generally been limited news in UK economic indicators relative to the Committee’s expectations in the August Monetary Policy Report. Headline GDP growth was expected to return to its underlying pace of around 0.3% per quarter in the second half of the year. Based on a broad set of indicators, the MPC judged that the labour market continued to loosen but that it remained tight by historical standards.

36: Twelve-month CPI inflation had been 2.2% in August, and was expected to increase to around 2½% towards the end of this year as declines in energy prices last year fell out of the annual comparison. Services consumer price inflation had remained elevated at 5.6% in August. Private sector regular average weekly earnings growth had declined to 4.9% in the three months to July. Households’ inflation expectations had largely normalised to close to their historical averages, although businesses’ inflation expectations had remained at slightly more elevated levels.

Bank Rate decision

37: Different members took different views on the probabilities and risks associated with the various cases that the Committee was considering, which were informing their votes on Bank Rate.

38: Eight members preferred to maintain Bank Rate at 5% at this meeting. Wage and price-setting had continued to normalise and UK activity growth had been broadly in line with expectations, although there was some greater uncertainty around the near-term global outlook. There was a range of views among these members on the degree to which the unwinding of past global shocks, the normalisation in inflation expectations and the current restrictive policy stance would lead underlying domestic inflationary pressures to continue to unwind, or whether these pressures could prove more entrenched, possibly as a result of more structural factors or greater momentum in demand. Despite these differences of view, the current policy stance was judged to be appropriate. For most members, in the absence of material developments, a gradual approach to removing policy restraint would be warranted.

39: One member preferred a 0.25 percentage point reduction in Bank Rate at this meeting. Bank Rate needed to become less restrictive now to enable a smooth and gradual transition in the policy stance, and to account for lags in transmission. CPI inflation had been on a firm downward trajectory for some time. Data developments remained consistent with CPI inflation staying sustainably at target, given the further easing in the labour market, continued falls in inflation expectations and forward-looking indicators of pass-through, and the subdued outlook for demand.

40: Monetary policy would need to continue to remain restrictive for sufficiently long until the risks to inflation returning sustainably to the 2% target in the medium term had dissipated further. The Committee continued to monitor closely the risks of inflation persistence and would decide the appropriate degree of monetary policy restrictiveness at each meeting.

41: The MPC would make a full assessment of recent and prospective developments as part of its forthcoming November forecast round.

Annual decision on the pace of reduction in the stock of UK government bond purchases held for monetary policy purposes

42: As set out in the minutes of its August 2022 meeting, the MPC had committed to review the reduction in the Asset Purchase Facility (APF) annually and, as part of that, to set an amount for the reduction in the stock of purchased UK government bonds (gilts) over the subsequent 12-month period. Box A of the August 2024 Monetary Policy Report had set out an assessment of the process of quantitative tightening over the previous year.

43: The Committee continued to judge that reducing the size of the APF had the benefit of reducing the risk of a ratchet upwards in the size of the Bank’s balance sheet over time, and thus should increase the headroom and flexibility available to the Bank to use its balance sheet in the future if needed.

44: The appropriate pace of gilt stock reduction would continue to be guided by a set of key principles, which the MPC had first outlined in the August 2021 Monetary Policy Report. First, the Committee intended to use Bank Rate as its active policy tool when adjusting the stance of monetary policy. Second, sales would be conducted so as not to disrupt the functioning of financial markets. Third, to help achieve that, sales would be conducted in a gradual and predictable manner over a period of time.

45: As set out in the Box in the August 2024 Report, the Committee judged that quantitative tightening had continued to proceed smoothly. There was no evidence of a negative impact of gilt sales on market functioning across a range of financial market measures. In particular, measures of gilt market liquidity had further improved. APF reduction was likely to have had some tightening effect on yields, which, while difficult to measure precisely, was judged to have been modest. That was in line with the MPC’s previous expectations, and was broadly consistent with findings from other empirical studies and central banks. The Committee would continue to learn from monitoring developments as the process progressed.

46: While it remained hard to measure precisely the marginal effect of quantitative tightening on the economy, the MPC’s forecasts were conditioned on asset prices that incorporated announced and expected APF reductions. The MPC had therefore taken this effect into account when setting the desired monetary policy stance using Bank Rate. Any tightening effect from the reduction in the APF would have led to a slightly lower path for Bank Rate, all else equal. Given that the impact of APF reduction was judged to have been modest, this was unlikely to have made a material difference to the appropriate path for Bank Rate over the past year.

47: The Committee considered the case to maintain the pace of gilt stock reduction at £100 billion over the 12 months ahead, of which £87 billion would be maturing APF gilt holdings. Bank staff had briefed the MPC on the current state of economic and market conditions. The Financial Policy Committee (FPC) had also been briefed on the MPC’s deliberations.

48: All members of the MPC agreed at this meeting that the Bank of England should reduce the stock of UK government bond purchases held for monetary policy purposes, and financed by the issuance of central bank reserves, by £100 billion over the 12-month period from October 2024 to September 2025, comprising both maturing gilts and sales.

49: The MPC also reaffirmed that there would be a high bar for amending the planned reduction in the stock of purchased gilts outside a scheduled annual review. That was in order to remain consistent with the principles that Bank Rate should be the active policy tool when adjusting the stance of monetary policy, and that APF reduction should be predictable. In judging whether that bar was met, the FPC would also have a role through its assessment of financial stability.

50: The Chair invited the Committee to vote on the propositions that:

  • Bank Rate should be maintained at 5%; and
  • The Bank of England should reduce the stock of UK government bond purchases held for monetary policy purposes, and financed by the issuance of central bank reserves, by £100 billion over the next 12 months, to a total of £558 billion.

51: Eight members (Andrew Bailey, Sarah Breeden, Megan Greene, Clare Lombardelli, Catherine L Mann, Huw Pill, Dave Ramsden and Alan Taylor) voted in favour of the first proposition. Swati Dhingra voted against this proposition, preferring to reduce Bank Rate by 0.25 percentage points, to 4.75%.

52: The Committee voted unanimously in favour of the second proposition.

Operational considerations

53: On 18 September 2024, the stock of UK government bonds held for monetary policy purposes was £659 billion.

54: At this meeting, the MPC had voted to reduce the stock of UK government bond purchases held for monetary policy purposes by £100 billion over the 12-month period from October 2024 to September 2025. The details of the first quarter of the associated gilt sales programme, covering 2024 Q4, were set out in a Market Notice accompanying these minutes. The Bank would continue to set auction sizes each quarter, to meet the MPC’s annual target as closely as practicable.

55: The following members of the Committee were present:

Andrew Bailey, Chair

Sarah Breeden

Swati Dhingra

Megan Greene

Clare Lombardelli

Catherine L Mann

Huw Pill

Dave Ramsden

Alan Taylor

Sam Beckett was present as the Treasury representative.

David Roberts was present on 12 September, and Jonathan Bewes on 16 September, as observers for the purpose of exercising oversight functions in their roles as members of the Bank’s Court of Directors.

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