Status: Please note you should read all Brexit changes to the FCA Handbook and BTS alongside the main FCA transitional directions. Where these directions apply the 'standstill', firms have the choice between complying with the pre-IP completion day rules, or the post-IP completion day rules. To see a full list of Handbook modules affected, please see Annex B to the main FCA transitional directions.


Status: This chapter was amended on 31 December 2020 as a result of Brexit. However, it is subject to the FCA Prudential Transitional Direction, which means that firms should not comply with these provisions yet. Instead, firms must follow this link and continue to comply with pre-IP completion day requirements https://www.handbook.fca.org.uk/handbook?date=31-12-2020&timeline=True (unless specified otherwise in the Direction). To see a full list of Handbook modules affected, please see Section B of the Annex to the Direction.

BIPRU 8 Annex 6 Non-UK regulators’ requirements deemed equivalent for individual risks

Part 1 (Non-UK banking regulators’ requirements deemed equivalent for individual risks)3

Regime regulators

Market risk

Credit

risk

Operational Risk

USA

Office of the Comptroller of the Currency

Board of Governors of the Federal Reserve System

* a US banking subsidiary will be deemed equivalent for credit risk if:

  • it is categorised as well capitalised: and
  • it scales up its US Basel 1 credit risk requirement by 25%

X*

X*

X

X

Australia

Australian Prudential Regulation Authority [APRA]

X

Canada

Office of the Superintendent of Financial Institutions [OSFI]

Switzerland Swiss Financial Market Supervisory Authority [FINMA]2

2

√ See note 2

Japan

Financial Services Agency, Japan [JFSA]

X

X

South Africa

South African Reserve Bank [SARB]

Hong Kong

Hong Kong Monetary Authority [HKMA]

Singapore

Monetary Authority of Singapore [MAS]

India

Reserve Bank of India [RBI]

Korea

Financial Supervisory Service [FSS]

X

X

1Jersey

1Guernsey

X

1Isle of Man

X

Note 1: A √ denotes that the requirements have been assessed as equivalent to EEA standards.

A X denotes that the requirements have been assessed as not being equivalent to EEA standards.

Note 2: √ International standardised approach only. The treatment of the Lombard loans is not equivalent and they must be treated under the appropriate regulator's rules.

Part 2 (Non-UK investment firm regulators’ requirements deemed equivalent for individual risks)3

Regime regulators

Market risk

Credit risk

Operational Risk

Australia

Sydney Futures Exchange

Australian Stock Exchange

X

X

X

X

Canada

Ontario Securities Commission

Quebec Securities Commission

British Columbia Securities Commission

Alberta Securities Commission

Investment dealers Association of Canada

X

X

X

X

X

X

X

X

X

X

Hong Kong

Hong Kong Monetary Authority [HKMA]

Hong Kong Securities and Futures Commission

X

X

X

X

Japan

Financial Services Agency, Japan [JFSA]

X

X

Singapore

Monetary Authority of Singapore [MAS]

Stock Exchange of Singapore

X

X

X

X

South Africa

South African Futures Exchange

Johannesburg Stock Exchange

Bond Exchange of South Africa

X

X

X

X

X

X

Switzerland

Swiss Federal Banking Commission [EBK]

√ Note 2

USA

Securities & Exchange Commission (SEC): Net Capital rule only

Commodities and Futures Trading Commission

√ Note 3

1

X

X

X

Note 1: A √ denotes that the requirements have been assessed as equivalent to EEA standards.

A X denotes that the requirements have been assessed as not being equivalent to EEA standards.

Note 2: √ International standardised approach only. The treatment of Lombard loans is not equivalent and they must be treated under the appropriate regulator's rules.

Note 3: √ Where entities are subject to a local regulatory capital requirement.