On 12 March 2024, the Bank of England (BoE) published Policy Statement PS5/24 on solvent exit planning for non-systemic banks and building societies, setting out how these types of firm in the UK should prepare, as part of their business-as-usual (BAU) activities, for an orderly ‘solvent exit’ and, if needed, be able to execute one.

PS5/24 provides feedback to responses to Consultation Paper CP10/23 and sets out the PRA’s final policy in relation to:

  • Chapter 7 of the Recovery Plans Part of the PRA Rulebook.
  • Supervisory Statement SS2/24 – Solvent Exit Planning for non-systemic banks and building societies.
  • Updated Supervisory Statement SS3/21 – Non-systemic UK banks: The PRA’s approach to new and growing banks.

Background

The PRA confirmed in its business plan for 2022/2023 that it would work to increase confidence that firms can exit the market with minimal disruption in an orderly way. As part of this programme of work, the PRA proposed in CP10/23:

  • New rules and expectations stating that a firm must prepare for a solvent exit as part of its BAU activities, and that a firm must document the preparations in a solvent exit analysis.
  • New expectations, which apply if solvent exit becomes a reasonable prospect for a firm, on how the firm should prepare a solvent exit execution plan and monitor and manage the execution of a solvent exit.
  • Consequential changes to SS3/21 such as the ‘Solvent wind down’ section for alignment.

The final policy

Having considered the responses to CP10/23, the PRA has implemented the policy largely as consulted on, with some changes to further clarify the PRA’s expectations. The key changes are:

  • SS2/24 (paragraph 1.3): the PRA provides further clarity and elaboration of a firm’s solvent exit planning for the transfer and/or repayment of all deposits; and the removal of a firm’s Part 4A PRA permission.
  • SS2/24 (paragraph 2.7): the PRA clarifies that a firm’s solvent exit indicators are intended to inform a firm as to when it may need to initiate a solvent exit, but they are not automatic triggers for a solvent exit.
  • SS2/24 (paragraph 2.18 and Annex A): the PRA adds examples of stakeholders in a firm’s solvent exit planning on communication.
  • SS2/24 (paragraph 2.25): the PRA clarifies that a firm may perform assurance activities internally, or externally as the firm considers appropriate.
  • SS2/24 (paragraph 3.7): the PRA provides further details on what a firm should consider regarding exit valuations.
  • The PRA has also made some editorial amendments to SS2/24 and SS3/21 to enhance clarity and consistency.

The PRA considers that the changes to its draft policy will not have a significant impact on firms.

Next steps  

Recovery Plans Chapter 7 will come into force on Wednesday 1 October 2025. Firms are also expected to meet the expectations in SS2/24 by the same date.