Respondents generally agreed with proposals by JER JFSC who met with all JIBs and received their input, and no concerns were raised in timeline or principles of roadmap.
Three areas highlighted as being very importance to get right when implementing the roadmap, including large exposures, systemic importance, and prudential reporting.
More clarity was requested on JER JFSC plans for workshops and consultations.
Concerns over JER JFSC fee increases, where JIBs use advanced approaches.
JER JFSC responded that it was to retain flexibility to react to international developments, such as the delays outlined in 1.2 of the feedback paper.
This includes EU's announcement of a delay to its market risk reforms, due Jan. 1, 2026, which was previously Jan. 1, 2025), and UK PRA delaying publication.
UK PRA delayed publication of its second near-final statement on Basel 3.1 until Sep. 12, 2024, covering credit risk issues and reporting, among other things.
JER JFSC provided greater clarity on the next steps and will continue to do so.
Feedback on fees will inform work on fees and will be addressed within that work.
Next Steps
In line with JER JFSC's roadmap, it will engage with Jersey Incorporated Banks (JIBs) on large exposures, operational risk and credit risk, before consultation in Q4 2024.
JER JFSC will reach out to all stakeholders in Q4 2024 on systemic importance, in advance of the planned consultation in H1 2025, regarding Basel III implementation.
By Oct. 2024-end, JER JFSC will publish final documentation on quick wins, and provide JIBs with finalized minima and buffer requirements.
These changes will be effective from Jan. 1, 2025.
