PwC's response to EBA discussion paper on new prudential framework for investment firms

This submission is made by PricewaterhouseCoopers LLP (PwC), the UK member firm of the PwC network. In the UK, we are the auditor of many regulated firms, as well as providing advisory services to a range of investment firms. Our practical experience of investment firms and their business models comes from a range of assignments. We also have a team of dedicated specialists focusing on the impact that new regulatory developments have on the financial services sector.

We welcome the opportunity to comment on the proposals and we are supportive of an approach which creates a new regime for investment firms. We believe that the way that the existing regime is developing under the Basel Committee will become increasingly difficult to reconcile to the business models of the vast majority of the firms that you intend to capture under the discussion paper and so a new regime is timely.

However, we have some reservations on the practical application of some of the proposals which we hope will be clarified when the more detailed proposals become available later in the year. Without clarity on these additional parts of the framework we do not feel able to give our full support, however we believe that the discussion paper provides the first step to a more appropriate regime.

This submission is not intended to represent the views of our clients, but rather to identify and to comment on certain aspects of the discussion paper on a new prudential framework for investment firms which we believe to have particular significance. 

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