The Financial Conduct Authority published observations from a multi-firm review of liquidity risk management across wholesale trading sell-side firms in scope of the Investment Firms Prudential Regime, setting out good and poor practices and the supervisory actions taken where weaknesses were identified. Across the 26 larger firms reviewed, the FCA found that some frameworks were not commensurate with firms’ size and the instantaneous nature of their liquidity risks, and it has used follow-up measures including Individual Liquidity Guidance and required attestations to support remediation. The review covers sell-side firms trading on own account and or providing clients with market access, including commodity clearing brokers, principal trading firms trading commodities, inter-dealer brokers and contracts-for-differences firms. In weaker firms, common issues included failing to identify the full range of liquidity risks (especially idiosyncratic risks), underestimating the size of exposures, over-reliance on immediate access to liquidity facilities, and contingency funding plans that were inoperable or lacked action triggers and a credible range of contingency actions. Firms typically modelled intraday (T0) and inter-day (T1) stressed cash outflows as the primary risk, with an average of 80% of stressed outflows occurring on T0 or T1. Supervisory follow-up included direct feedback to all firms, setting Individual Liquidity Guidance and requiring an attestation and assurance report for 14 firms where weaknesses included underestimated liquid asset threshold requirements, requesting attestations and assurance from a further three firms, and issuing improvement feedback to nine firms. The FCA emphasised that the paper does not change policy or rules and pointed firms to existing MIFIDPRU requirements. It will also run workshops and roundtables with firms and industry bodies to discuss the findings and promote adoption of good practices, and it signalled continued use of supervisory tools where liquidity risks are not being properly managed.
Financial Conduct Authority 2025-03-07
Financial Conduct Authority identifies liquidity risk management weaknesses at sell-side IFPR firms and sets Individual Liquidity Guidance for 14 firms
The Financial Conduct Authority (FCA) reviewed liquidity risk management among wholesale trading sell-side firms under the Investment Firms Prudential Regime. It found deficiencies in some firms' frameworks, particularly in addressing idiosyncratic risks and contingency planning. The FCA has taken supervisory actions, including Individual Liquidity Guidance and required attestations, and will continue engaging with firms to promote best practices without altering existing MIFIDPRU requirements.