The UK government announced on 14 October 2024 in a ministerial statement that it intended to raise the threshold for the ring-fencing (separation) of retail and investment banking activities of large UK-based banks. These banks are known as ‘systemically important financial institutions (SIFIs)’, which are currently defined as those with more than £25bn of core retail deposits. Under the new regulations, the threshold would rise from £25bn to £35bn.
Ring-fencing is the separation of one set of banking services from another. This separation can be geographical or functional. The UK adopted the latter approach, where ring-fencing is the separation of core retail banking services, such as taking deposits, making payments and granting loans to small and medium-sized enterprises (SMEs) from investment banking and international operations. The intention of ring-fencing was to prevent contagion – to protect essential retail banking services from the risks involved in investment banking activities.
Reducing regulation to increase competition
Raising the limit is intended to facilitate greater competition in the retail banking sector. In recent years, US banks, such as JP Morgan and Goldman Sachs, have been expanding their depositor base in the UK under their respective brands – Chase UK and Marcus.
These relatively small UK subsidiaries were not ring-fenced from their wider investment banking operations as their retail deposits were under (but not far under) the £25bn limit. However, this restricted their ability to increase market share further without bearing the additional regulatory burden associated with ring-fencing that much larger incumbents face. Raising the threshold would allow them to expand to the higher limit without the regulatory burden.
The proposals are part of a broader package of reforms aimed at reducing the regulatory burden on UK-based banks. The hope is that this will stimulate greater lending to SMEs to boost investment and productivity.
The proposals also include a new ‘secondary’ threshold. This will exempt banks providing primarily retail banking services from the rules governing the provision of investment banking accounts. This exemption will apply as long as their investment banking is less than 10% of their tier 1 capital. (Tier 1 capital is currently the buffer which banks are required to retain in case of a crisis.) The changes were the outcome of a review conducted in 2022 but had not been implemented by the previous government.
The announcement has sparked a debate about ring-fencing, with some commentators calling for it to be removed altogether. Therefore, it is timely to revisit the rationale for ring-fencing. This blog examines what ring-fencing is and why it was introduced, and explains the associated economic costs and benefits.
Why was ring-fencing introduced?
Ring-fencing was recommended by the Independent Commission on Banking (ICB) in 2011 (see link below) and implemented through the Financial Services (Banking Reform) Act of 2013. The proposed separation of core retail banking services from investment banking were intended to address issues in banks which arose during the global financial crisis and which required substantial taxpayer bailouts. (See the 2011 blog, Taking the gambling out of high street banking (update).)
Following deregulation and liberalisation of financial services in the 1980s, many UK banks had extended their operations so that they combined domestic retail operations with substantial investment and international operations. The intention was to open up all dimensions of financial services to greater competition and allow banks to exploit economies of scope between retail and investment banking.
However, the risks associated with these services are very different but, in the period before the financial crisis, were provided alongside one another within banking groups.
One significant risk which was not fully recognised at the time was contagion – problems in one dimension of a bank’s activity could severely compromise its ability to provide services in other areas. This is what happened during the financial crisis. Many of the UK banks’ investment operations had made significant investments in off-balance sheet securitised debt instruments – CDOs being the most famous example. (See the 2018 blog, Lehman Brothers: have we learned the lessons 10 years on?.)
When that market crashed in 2007, several UK-based banks incurred significant losses, as did other banks around the world. Given their thin equity buffers and the inability to borrow due to a credit crunch, such banks found it impossible to bear these losses.
The UK government had to step in to save these institutions from failing. If it had not, there would have been significant economic and social costs associated with their inability to provide core retail banking functions. (See the 2017 blog, Ten years on.)
The Independent Commission proposed that ‘the risks inevitably associated with banking have to sit somewhere, and it should not be with taxpayers. Nor do ordinary depositors have the incentive (given deposit insurance to guard against runs) or the practical ability to monitor or bear those risks’ (p.9). Unstructured banks, with no separation of retail from investment activities, increase the potential for both of these stakeholder groups to bear the risks of investment banking.
Structural separation of retail and investment banking addresses this problem. First, separation should make it easier and less costly to resolve problems for banks that get into trouble, avoiding the need for taxpayer bailouts. Second, structural separation should help to insulate retail banking from external financial shocks, ensuring that customer deposits and essential banking services are protected.
Problems of ring-fencing
Ring-fencing has been subject to criticism, however, which has led to calls for it to be scrapped.
It must be noted that most of the criticism comes from banks themselves. They state that it required significant operational restructuring by UK banks subject to the regulatory framework which was complex and costly.
In addition, segregating activities can lead to inefficiencies, as banks may not be able to take full advantage of economies of scope between investment and retail banking. Furthermore, ring-fencing could lead to a misallocation of capital, where resources are trapped in one part of the bank and cannot be used to invest in other areas, potentially increasing the risks of the specific areas.
Assessing the new proposals
It is argued that the increased threshold proposed by the authorities may put UK institutions at a competitive disadvantage to outside entrants that are building market share from a low base. Smaller entrants do not have to engage in the costly restructuring that the larger UK incumbents have. They can exploit scope economies and capital mobility within their international businesses to cross-subsidise their retail services in the UK which incumbents with larger deposit-bases are not able to.
However, the UK market for retail banking has significant barriers to entry. Following the acquisition of Virgin Money by Nationwide, only six banking groups in the UK meet the current threshold (Barclays, HSBC, Lloyds Banking Group, NatWest Group, Santander UK and TSB). Indeed, all of those have deposits well above the proposed £35bn threshold. Consequently, raising the threshold should not add significant compliance and efficiency costs, while the potential benefits of greater competition for depositors and SMEs could be a substantial boost to investment and productivity. Furthermore, if the new US entrants do suffer problems, it will not be UK taxpayers who will be liable.
Have we been here before?
In many ways, ring-fencing is a throwback to a previous age of regulation.
One of the most famous Acts of Congress relating to finance and financial markets in the USA is the Glass-Steagall Act of 1933. The Act was passed in the aftermath of the 1929 Wall Street crash and the onset of the Great Depression in the USA. That witnessed significant bank failures across the country and problems were traced back to significant losses made by banks in their lending to investors during the speculative frenzy that preceded the stock market crash of 1929.
To prevent a repeat of the contagion and ensure financial stability, Glass-Steagall legislated to separate retail banks and investment banks.
In the UK, such separation had long existed due to the historical restrictions placed on investment banks operating in the City of London. In the late 20th century, the arguments for separation became outweighed by arguments for the liberalisation of markets to improve efficiency and competition in financial services. Banking was increasingly deregulated and separation disappeared as retail banks increasingly engaged in investment activities.
That cycle of deregulation reached its nadir in 2007 with the international financial crisis. The need to bail out banks made it clear that the supposed synergies between investment and retail banking were no compensation for the high costs of contagion in the financial system.
Regulators must be wary of calls for the removal of ring-fencing. Sir John Vickers (chairman of the independent commission on banking) highlighted the need to protect depositors, and more importantly taxpayers, from risks in banking. It is the banks that should bear the risks and manage them accordingly. Ultimately, it is up to the banks to do that better.
Articles
Bank annual reports
Access these annual reports to check the deposit base of these UK banks:
Information
Report
- Final Report: Recommendations
The Independent Commission on Banking, Sir John Vickers (Chair), Clare Spottiswoode, Martin Taylor, Bill Winters and Martin Wolf (September 2011)
Questions
- How did the structure of UK banks cause contagion risk in the period before the global financial crisis?
- How does ring-fencing aim to address this and protect depositors and taxpayers?
- Use the links to the annual reports of the covered banks to assess the extent of deposits held by the institutions in 2023. How far above the proposed buffer do the banks sit?
- Use your answer to 3) and economic concepts to analyse the impact on competition in the UK market for retail deposits of raising the threshold.
- What are the risks for financial stability of raising the threshold?
Insolvencies in England and Wales have fallen to their lowest level since 2005, official records show. The Insolvency Service indicates that bankruptcy, individual voluntary arrangements and debt relief orders have fallen, with the largest and worst form of bankruptcy falling by 22.5 per cent compared to the same period in 2014. There has also been a fall in corporate insolvencies back to pre-crisis levels.
The British economy is recovering and despite an increase in consumer borrowing of £1.2 billion from February to March, which is the biggest since the onset of the credit crunch, the number of people in financial difficulty and living beyond their means has fallen. However, there are also suggestions that the number could begin to creep up in the future and we are still seeing a divide between the north and south of England in terms of the number of insolvencies.
There are many factors that could explain such a decline in insolvencies. Perhaps it is the growth in wages, in part due the recovery of the economy, which has enabled more people to forgo borrowing or enabled them to repay any loan more comfortably. Lower inflation has helped to reduce the cost of living, thereby increasing the available income to repay any loans. Interest rates have also remained low, thus cutting the cost of borrowing and the repayments due.
But, another factor may simply be that lending is now more closely regulated. Prior to the financial crisis, huge amounts of money were being lent out, often to those who had no chance of making the repayments. More stringent affordability checks by lenders may have a large part to play in reducing the number of insolvencies. President of R3, the insolvency practitioner body, Phillip Sykes said:
“It may be too early to draw conclusions but demand could be falling as a result of low interest rates, low inflation and tighter regulation. This trend is worth watching.”
Mark Sands, from Baker Tilly added to this, noting that fewer people were now in financial difficulty.
“As well as this, we are seeing lower levels of personal debt and fewer people borrowing outside of their means due to more stringent affordability checks by creditors.”
Whatever the main reason behind the data, it is certainly a positive indicator, perhaps of economic recovery, or that at least some have learned the lessons of the financial crisis. The following articles consider this topic.
Personal insolvencies fall to 10-year low Financial Times, James Pickford (1/5/15)
Personal insolvencies at lowest level since 2005 BBC News (29/4/15)
Personal insolvencies drop to lowest level in a decade The Guardian, Press Association (29/4/15)
Corporate insolvencies at lowest level since 2007 The Telegraph, Elizabeth Anderson (30/4/15)
Interview: R3 President Phillip Sykes Accountancy Age, Richard Crump (1/5/15)
North-South gap widens in personal insolvencies Independent, Ben Chu (27/4/15)
Insolvency rates show ‘stark’ north-south divide Financial Times, James Pickford (27/4/15)
Questions
- What is meant by insolvency?
- There are many factors that might explain why the number of insolvencies has fallen. Explain the economic theory behind a lower inflation rate and why this might have contributed to fewer insolvencies.
- How might lower interest rates affect both the number of personal and corporate insolvencies?
- Why has there been a growth in the north-south divide in terms of the number of insolvencies?
- Do you think this data does suggest that lessons have been learned from the Credit Crunch?
On 15 September 2008, Lehman Brothers, the fourth-largest investment bank in the USA, filed for bankruptcy. Although the credit crisis had been building since mid 2007, the demise of Lehmans was a pivotal event in the unfolding of the financial crisis and the subsequent severe recession in most developed economies. Banks were no longer seen as safe and huge amounts of government money had to be poured into banks to shore up their capital and prevent further bankruptcies. Partial nationalisation seemed the only way of rescuing several banks and with it the global financial system.
A deep and prolonged recession followed (see Chart 1: click here for a PowerPoint). In response, governments pursued expansionary fiscal policies – at least until worries about rising government deficits and debt caused a lurch to austerity policies. And central banks pursued policies of near zero interest rates and subsequently of quantitative easing. But all the time debate was taking place about how to reform banking to prevent similar crises occurring in the future.
Solutions have included reform of the Basel banking regulations to ensure greater capital adequacy. 
The Basel III regulations (see Chart 2) demand considerably higher capital ratios than the previous Basel II regulations.
Other solutions have included proposals to break up banks. Indeed, just this week, the Lloyds Banking Group has hived off 631 of its branches (one sixth of the total) into a newly reformed TSB. Another proposal is to ring-fence the retail side of banks from their riskier investment divisions. In both cases the aim has been to avoid the scenario where banks are seen as too big to fail and can thus rely on governments to bail them out if they run into difficulties. Such reliance can make banks much more willing to take excessive risks. Further details of the new systems now in place are given in the Robert Peston article below.
But many critics maintain that not nearly enough has been done. Claims include:
• The Basel III rules are not tough enough and banks are still being required to hold too little capital.
• Rewards to senior bankers and traders are still excessive.
• The culture of banking, as a result, is still too risk loving in banks’ trading arms, even though they are now much more cautious about lending to firms and individuals.
• This caution has meant a continuing of the credit crunch for many small businesses.
• Higher capital adequacy ratios have reduced bank lending and have thus had a dampening effect on the real economy.
• The so-called ring-fences may not be sufficient to insulate retail banking from problems in banks’ investment divisions.
• Banks are not being required to hold sufficient liquidity to allow them to meet customers’ demands for cash in all scenarios.
• Banks’ reliance on each other still leaves a systemic risk for the banking system as a whole.
• Fading memories of the crisis are causing urgency to tackle its underlying problems to diminish.
• Problems may be brewing in less regulated parts of the banking world, such as the growing banking sector in China.
The following articles look at the lessons of the banking crisis – those that have been learned and those that have not. They look at the measures put in place and assess whether they are sufficient.
Lehman Brothers collapse, five years on: ‘We had almost no control’ The Guardian, Larry Elliott and Jill Treanor (13/9/13)
Lehman Brothers collapse: five years on, we’re still feeling the shockwaves The Guardian, Larry Elliott (13/9/13)
Five years after Lehman, could a collapse happen all over again? The Observer, Larry Elliott and Jill Treanor (15/9/13)
Five years after Lehman, all tickety-boo? BBC News, Robert Peston (9/9/13)
What have we learned from the bank crash? Independent, Yalman Onaran, Michael J Moore and Max Abelson (14/9/13)
We’ve let a good financial crisis go to waste since Lehman Brothers collapsed The Telegraph, Jeremy Warner (12/9/13)
The Lehman legacy: Lessons learned? The Economist (9/9/13)
The dangers of debt: Lending weight The Economist (14/9/13)
The Lehman anniversary: Five years in charts The Economist (14/9/13)
Questions
- Why did Lehman Brothers collapse?
- Explain the role of the US sub-prime mortgage market in the global financial crisis of 2007/8.
- In the context of banking, what is meant by (a) capital adequacy; (b) risk-based capital adequacy ratios; (c) leverage; (d) leverage ratios?
- Explain the Basel III rules on (a) risk-based capital adequacy (see the textbook and the chart above); (b) non-risk-based leverage (introduced in 2013: see here for details).
- Explain and comment on the following statement by Adair Turner: ‘We created an over-leveraged financial system and an over-leveraged real economy. We created a system such that even if the direct cost of bank rescue was zero, the impact of their near-failure on the economy was vast.’
- Under what circumstances might the global financial system face a similar crisis to that of 2007/8 at some point in the future?
- Why is there an underlying conflict between increasing banks’ required capital adequacy and ensuring a sufficient supply of credit to consumers and business? What multiplier effects are likely to occur from an increase in the capital adequacy ratio?
Over the past few years, the term ‘bail-out’ has been a common phrase. But, what about the term ‘bail-in’? The latest bank to face financial ruin is the Co-operative Bank, but instead of turning to the tax-payer for a rescue, £1.5 billion will come from bond holders being offered shares in the bank. This will mean that the bank will become listed on the stock market.
Back in 2009, the Co-operative Bank bought Britannia Building Society and it seems that this was the start of its downfall. It took over many bad mortgage loans and loans to companies, and these played a large part in its current financial difficulties.
In order to rescue the bank and raise the capital needed to absorb current and future losses, without turning to the tax-payer, bond-holders of £1.3 billion of loans to the bank will be asked to swap them for shares and bonds, thus leading to significant losses for them. These bond-holders include 7000 private investors.
Since the financial crisis five years ago, the conventional banking model has seen much criticism and many suggested that the mutual structure of the Co-operative provided a better model, creating trust, due to its many stakeholders, who are not as focused on profitability and returns as those shareholders of a listed bank. However, the problems of the Co-operative seem to have put paid to that idea. The bail-in will mean that the bank is now listed on the stock market and thus will have shareholders expecting returns and profitability. This will undoubtedly change the focus of the bank. Euan Sutherland, the new Chief Executive said:
We are very clear that the bank will remain true to responsible and community-based banking and retain its ethical investment stance … Clearly there are lessons to learn and clearly there will be a time to look back and do that but, to be honest, in the last six weeks, where I have been involved with the Co-operative group, we have focused on driving a very solid future for this bank.
The good news is that the savings of those in the Co-operative are safe and taxpayers will not have to fork out any more money.
Yet, the co-operative structure of the bank has long been praised by customers and government alike. But is it perhaps this structure, which has led to its collapse? Furthermore, will the change in structure that will see it listed on the stock market, lead to a change in its approach to banking? The following articles consider the latest bank to run into difficulties.
Webcast
Co-op Bank unveils rescue plan to tackle the £1.5bn hole BBC News (17/6/13)
Articles
Co-op Bank travails show weakness of mutual model Financial Times, Sarah Gordon (21/6/13)
Co-operative Bank to list on stock market in rescue deal The Guardian, Jill Treanor (17/6/13)
Troubled Co-operative Bank unveils rescue plan to plug £1.5bn hole in balance sheet Independent, Nick Goodway (17/6/13)
Co-op Bank announces plan to plug £1.5bn hole Which? (17/6/13)
The Co-operative Bank and the challenge of finding co-op capital The Guardian, Andrew Bibby (13/6/13)
Co-op Bank seeks to fill £1.5bn capital hole Sky News (17/6/13)
Does Co-op Group deserve to keep control of Co-op Bank? BBC News, Robert Peston (9/7/13)
Questions
- Why did the Co-operative Bank move into financial trouble?
- What are the key characteristics of a Mutual? Are they disadvantages or advantages?
- What is a ‘bail-in’? Who will gain and who will lose?
- The Co-operative Bank will now be listed on the stock market. What does this mean?
- What are the advantages and disadvantages of floating a company on the stock market?
- Why are all banks required to hold capital to absorb losses?
The housing market is crucial in any economy, as it provides so many jobs in related industries. It is frequently a good signal of how buoyant the economy is. With recession in the UK, mortgage rationing continuing and many homeowners having to find 20% deposits to buy a house, many would expect the housing market to be showing signs of trouble.
And to some extent this is the case. Studies on house prices have clearly shown how unpredictable this market is and prices remain 0.7% below what they were a year ago. However, in August house prices increased, recording their biggest rise in two and a half years, at 1.3%. For many, this rise was a surprise, but came as a welcome relief following the declines in previous months. Despite this rise, analysts have suggested that this trend is unlikely to continue throughout the rest of the year, as the demand for houses remains weak. Robert Gardner, the Chief Economist at Nationwide said:
“Given the difficult economic backdrop, the extent of the rebound in August is a little surprising. However, we should never read too much into one month’s data, especially since monthly price changes have been impacted by a number of one-off factors this year, such as the ending of the stamp duty holiday for first time buyers’.
So, what is behind this upward trend? Nationwide’s Chief Economist says that it could be explained by a resilient labour market, where employment has risen in recent months, despite the recession. The labour market undoubtedly has a big effect on the housing market, as mortgages do take up so a large percentage of take-home pay.
However, another key factor that affects house prices is the availability of mortgages. The Bank of England and Treasury launched the Funding for Lending Scheme at the beginning of August in a bid to make mortgages cheaper and more easily available. However, analysts suggest that the scheme is yet to have an effect. Furthermore, until deposit requirements are eased, that first step on the property ladder will remain elusive for many people. Mortgage approvals did increase slightly in July, but still remain a major barrier for the housing market to really boom.
The following articles consider this ‘surprising’ rise in house prices and the factors behind it.
Articles
House prices in ‘surprising’ jump, Nationwide says BBC News (31/8/12)
UK house prices record surprise increase Financial Times, Tanya Powley (31/8/12)
Surprise house price rise in August not indicative of market, says Nationwide The Telegraph, Emma Wall (31/8/12)
House prices in surprise rebound Independent, Vicky Shaw (31/8/12)
House prices continue to hold The Economic Voice, Jeff Taylor (31/8/12)
Mortgage approvals still subdued, Bank of England says BBC News (30/8/12)
Banks are pulling back from property – expect prices to fall Money Week, Matthew Partridge (31/8/12)
UK house prices up, as London continues surge Share Cast, Michael Miller (29/8/12)
Data
Lending to Individuals Bank of England 2012
House Price Index Land Registry 2012
UK house prices (links) Economics Network
Questions
- Use a supply and demand diagram to analyse recent trends in the housing market.
- Why is the Bank of England’s lending scheme not having the expected impact on the housing market?
- To what extent do you think the state of the housing market depends on mortgage rationing? Which other factors are likely to affect the housing market?
- In the article from the Economic Voice, the author says that house prices holding as they are is a surprise, because of relatively high inflation and the fact that wages are not keeping pace. Explain the economic thinking behind this view.
- The Chief Economist at Nationwide has said that the future of the housing market depends heavily on what happens to the labour market. Why is this the case?
- Why have mortgages been rationed and minimum deposit requirements been increased?
- Why is the housing market so important for the economy?
