Overview

The recent publication of the Liikanen Report represented the main outstanding piece in the global jigsaw of proposals as to structural reform of banks and other financial institutions. This high-level comparison table from Linklaters outlines the proposals' main similarities and differences in the EU, UK and US.

In the EU, the table covers not only the Liikanen Report, but also related proposed legislation such as the Bank Recovery and Resolution Directive. In the UK, the table mainly focuses on the proposals stemming from the Vickers Report; and in the US, the table covers the Volcker Rule, the swaps push-out rule and other aspects of Dodd-Frank, as well as existing structural separation regimes for insured deposit-taking banks.

Although the table does not go into other areas of prudential regulatory reform, such as the compulsory clearing of derivatives, depositor preferences or remuneration controls, it does touch on some areas such as bail-in and capital buffers which, whilst not strictly within the universe of structural reform, are mentioned specifically in the Liikanen Report.

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