Financial Stability Board
Climate-related financial risks - FSB publishes stocktake report of financial authorities’ financial stability monitoring - 22 July 2020
The Financial Stability Board (FSB) has published a stocktake report of financial authorities’ experience in accounting for physical and transition climate-related financial risks as part of their financial stability monitoring. The report draws on information provided by FSB member national authorities, international bodies and a workshop with the private sector.
Among other things, the report states that approximately three-quarters of respondents consider, or are planning to consider, climate-related financial risks as part of their financial stability monitoring. Most respondents indicate that their main focus concerns the implications of climate risks on asset prices and credit quality, and a minority also consider climate-related implications for underwriting, legal, liability and operational risks. The report also states that climate-related risks are beginning to be integrated into authorities’ micro-prudential supervision of banks and insurance firms, although this work is generally at an earlier stage than for other types of risk.
The FSB intends to carry out further work on climate-related financial risks by October 2020, including assessing how physical and transition risks could affect the financial system.
FSB stocktake report of financial authorities’ experience in accounting for physical and transition climate-related financial risks as part of their financial stability monitoring
Webpage
Press release
European Commission
Cross-border payments - European Commission adopts legislative proposal for a new Regulation - 17 July 2020
The European Commission has adopted a legislative proposal for a new Regulation on cross-border payments in the Union (2020/0145(COD)). The proposed Regulation aims to codify the existing Regulation on cross-border payments (924/2009/EU), in line with the Commission’s policy to codify legislative acts after they have been amended at least ten times. The proposed Regulation will preserve the content of the existing Regulation while repealing and replacing it.
The proposed Regulation will now be considered by the Council of the European Union and the European Parliament under the accelerated legislative process that applies to codification proposals. The Commission intends for the proposed Regulation to enter into force on 20 April 2021.
European Commission proposed Regulation (2020/0145(COD)) on cross-border payments in the Union
Annexes
BMR - European Commission adopts Delegated Regulations on EU climate transition benchmarks - 17 July 2020
The European Commission has announced that it has adopted three Commission Delegated Regulations supplementing the Benchmarks Regulation (EU) 2016/1011 (BMR) with regards to sustainable finance and financial benchmarking. The Commission consulted on draft versions of the texts in April 2020. The Delegated Regulations set out:
- minimum standards and transparency requirements for EU climate transition benchmarks;
- minimum standards setting out how environmental, social and governance (ESG) factors are to be reflected in benchmark statements; and
- minimum standards setting out how ESG factors are to be reflected in benchmark methodologies.
The Commission was mandated to produce these Delegated Regulations following amendments made to the BMR by the Low Carbon Benchmarks Regulation (EU) 2019/2089), which was published in the Official Journal of the European Union in December 2019.
Commission Delegated Regulation setting out minimum standards and transparency requirements for EU climate transition benchmarks
Commission Delegated Regulation setting out minimum standards setting out how ESG factors are to be reflected in benchmark statements
Commission Delegated Regulation setting out minimum standards setting out how ESG factors are to be reflected in benchmark methodologies
Webpage
Press release
Council of the European Union
EU crowdfunding legislative proposals - Council of the EU adopts Regulation and Directive - 20 July 2020
The Council of the European Union has adopted at first reading proposed Regulation (EU) 2018/0048(COD) on European crowdfunding service providers (ECSPs) for business and proposed Directive (EU) 2018/0047(COD), which makes consequential amendments to the Markets in Financial Instruments Directive (2014/65/EU) (MiFID II) in relation to crowdfunding. The Council of the EU published the final compromise texts of both the proposed Regulation and the proposed Directive in April 2020.
The Regulation and Directive aims to establish a new framework to remove barriers for crowdfunding platforms to provide their services cross-border by harmonising the minimum requirements when operating in their home market and other EU countries.
The next step is for the European Parliament to adopt the proposed legislation at second reading, after which it can be published in the Official Journal of the European Union.
Press release: Council of the EU adopts Regulation and Directive on EU crowdfunding service providers
European Banking Authority
CRR - EBA consults on draft Guidelines specifying conditions for the application of the alternative treatment of institutions’ tri-party repurchase agreement exposures - 22 July 2020
The European Banking Authority (EBA) has published for consultation draft Guidelines specifying the conditions for the application of the alternative treatment of institutions’ exposures related to ‘tri-party repurchase agreements’ under Article 403(3) of the Capital Requirements Regulation (575/2013/EU) (CRR) for large exposures purposes.
Pursuant to Article 403(3) of the CRR (and in the context of the mandatory substitution approach set forth in Article 403(1) of the CRR), an institution may replace the total amount of its exposures to a collateral issuer due to tri-party repurchase agreements facilitated by a tri-party agent, using as an alternative treatment the full amount of the limits that the institution has instructed the tri-party agent to apply to the securities issued by that collateral issuer. The amount of such a limit must be added to any other exposures to the same collateral issuer (direct loans, participations, etc.) with the overall amount, and including exposures to a relevant group of connected clients. Irrespective of the use of this treatment, institutions remain responsible for monitoring their exposures and complying at all times with the large exposure limits.
The draft Guidelines specify the conditions under which institutions may utilise Article 403(3), including the frequency for determining, monitoring and revising the full amount of the limits instructed by the institution to the tri-party agent. The draft Guidelines also recommend a set of elements that an institution and a tri-party agent should include in their service agreement, including the safeguards a tri-party agent must put in place and how institutions should determine the limits to be applied by the tri-party agent with regard to the securities of a collateral issuer.
The consultation period closes on 22 October 2020. National competent authorities will have two months following the publication of the official EU language translations of the final Guidelines to report whether they intend to comply with the Guidelines. The Guidelines will apply from June 2021.
EBA Consultation Paper on draft Guidelines specifying the conditions for the application of the alternative treatment of institutions’ exposures under Article 403(3) of the CRR
Webpage
Press release
CRR - EBA consults on draft RTS on estimating default probabilities and losses given default - 22 July 2020
The EBA has published for consultation draft regulatory technical standards (RTS) on the requirements that institutions’ internal methodologies and default risk models are to fulfil when using the Internal Models Approach (IMA) to estimate default probabilities and losses given default under Article 325bp(12) of the CRR.
Institutions using the IMA to compute own funds requirements for market risk are required to compute additional own funds requirements using an internal default risk model for their positions in traded debt and equity instruments included in IMA trading desks.
The draft RTS clarify the requirements to be met for the estimation of default probabilities and losses given default under the default risk model and specify that any internal methodology used to calculate these estimations under the default risk model should meet all requirements applied for the internal ratings‐based (IRB) approach. The RTS also specify the requirements that external sources are to fulfil for their use under the default risk model, reflecting similar qualitative requirements as those applicable to an internal model methodology.
The consultation period closes on 22 October 2020.
EBA Consultation Paper on draft RTS on estimating default probabilities and losses given default for institutions using the IMA under the CRR
Press release
Benchmarking of remuneration practices - EBA publishes report - July 2020
The EBA has published a report on the benchmarking of remuneration practices within the EU and associated data on high earners. The report is required by Article 75 of the Capital Requirements Directive (2013/36/EU) (CRD IV) and covers the remuneration practices in EU banks for the financial years 2017 and 2018 and high earners data for 2018.
Among other things, the report illustrates that:
- the number of high earners in EU banks receiving a remuneration of more than €1 million increased slightly by 1.58%, from 4,861 in 2017 to 4,938 in 2018;
- the number of high earners in EU banks has increased from 3,427 in 2010 to 4,938 in 2018; and
- the average ratio of variable to fixed remuneration for all high earners in the EU/EEA increased from 127% in 2014 to 139% in 2018. The observed remuneration levels of high earners reached up to €39 million.
EBA report on the benchmarking of remuneration practices in the EU
Press release
CRR - EBA calls for more information for its study on the cost of compliance with supervisory reporting - 22 July 2020
The EBA has published, among other things, a questionnaire for all EU credit institutions to complete as part of its study on the cost of compliance with supervisory reporting requirements. Under Article 430(8) of the CRR, the EBA is mandated to measure the costs that institutions incur when complying with supervisory reporting requirements. The EBA launched its study on the cost of compliance with supervisory reporting in June 2020.
The questionnaire aims to collect information in order to assess how best to optimise supervisory reporting requirements and reduce reporting costs for institutions. The questionnaire is split into two parts with different deadlines for responses, in order to take account of the challenges posed by the COVID-19 pandemic. The deadline for responses to the qualitative questions is 1 October 2020, and the deadline for responses to the quantitative questions is 31 October 2020.
The EBA has also launched a call for case studies to collect evidence on reporting costs as well as industry views on ways to reduce these costs and make supervisory reporting more efficient. The deadline for the submission of case studies is 31 October 2020. The final report to be developed by the EBA following the analysis of the industry responses will include recommendations on how to reduce reporting costs for the banking industry as a whole and, in particular, for small and non-complex institutions, by looking at both technological improvements and reducing some reporting requirements, where the costs outweigh the benefits.
Press release: EBA calls for more information for its study on the cost of compliance with supervisory reporting
EBA questionnaire on institutions’ cost of compliance with supervisory reporting requirements
Webpage
CRR - EBA consults on draft RTS on the determination of indirect exposures to underlying clients of derivatives and credit default derivatives - 23 July 2020
The EBA has published for consultation draft RTS specifying how institutions should determine exposures arising from derivative and credit derivative contracts, not entered directly into with a client but whose underlying debt or equity instrument was issued by a client, under Article 390(9) of the CRR. The draft RTS aim to ensure appropriate levels of consistency within the regulatory framework for the calculation of exposures for large exposure purposes.
The draft RTS propose a methodology for the calculation of indirect exposures for different categories of derivative contracts and credit derivative contracts with a single underlying debt or equity instrument, including: (i) options on debt and equity instruments; (ii) credit derivative contracts; and (iii) other derivatives having an underlying debt or equity instrument. The draft RTS also provide a separate methodology for the calculation of exposures stemming from contracts with multiple underlying reference names.
The consultation period closes on 23 October 2020.
EBA Consultation Paper on draft RTS on the determination of indirect exposures to underlying clients of derivatives and credit default derivatives under the CRR
Webpage
Press release
COVID-19 - EBA publishes Guidelines on the 2020 SREP - 23 July 2020
The EBA has published its final Guidelines on how competent authorities can exercise flexibility and pragmatism in their supervisory approaches to the 2020 supervisory review and evaluation process (SREP) in light of the economic impact and disruption caused by the COVID-19 pandemic.
The Guidelines adapt the conduct of the SREP to the special circumstances brought about by the crisis, and cover: (i) the focus of the pragmatic 2020 SREP; (ii) overall 2020 SREP assessment and scoring; (iii) supervisory measures; and (iv) conduct of the SREP in cross‐border contexts. The focused SREP approach ensures the implementation of the overall SREP assessment in the context of COVID-19 through undertaking a risk‐driven assessment focusing mainly on the most material risks and vulnerabilities driven by the COVID-19 crisis and the ability of an institution to respond to the challenges brought by the crisis, including operational continuity.
A distinct feature of the pragmatic 2020 SREP approach is that, while the institution‐specific nature of the exercise is preserved, the Guidelines identify a set of risks and vulnerabilities that are deemed the most material in the context of this crisis and place emphasis on the supervisory assessment of these items. The EBA states that the institution‐specific nature of the SREP ensures that any additional risk deemed material for an institution in the context of this crisis, in particular market risk, would also be subject to supervisory scrutiny.
EBA Guidelines on the 2020 SREP in light of COVID-19
European Central Bank
Benchmark rate reforms - ECB publishes report on banks’ preparations - July 2020
The European Central Bank (ECB) has published a report on banks’ preparedness for benchmark rate reforms. The report includes good practice guidance outlining how banks can best structure their benchmark rate-related governance and identify benchmark reform-related risks.
Among other things, the report states that while banks are generally well aware of the complexity of the reforms and the challenges involved, their level of preparation leaves room for improvement. The report also states that banks are generally behind schedule in implementing risk mitigation measures and have tended to focus more on the transition from the euro overnight index average (EONIA) to the euro short-term rate (€STR) than on the risks associated with the reform of the euro interbank offered rate (EURIBOR). This is despite the fact that EURIBOR is currently the most frequently used benchmark rate for contracts in the euro area.
ECB report on banks’ preparations for benchmark rate reforms
Press release
Official Journal of the European Union
EEA Agreement - Decisions amending Annex IX (Financial Services) published in the Official Journal - 2 July 2020
EEA Joint Committee Decisions 17/2019, 19/2019 and 20/2019 of 9 February 2019, which amend Annex IX (Financial Services) to the EEA Agreement, have been published in the Official Journal of the European Union.
The Decisions amend Annex IX (Financial Services) to incorporate several Implementing and Delegated Regulations concerning various aspects of the Solvency II Directive (2009/138/EC), the Bank Recovery and Resolution Directive (2014/59/EU) (BRRD) and the Central Securities Depositories Regulation (909/2014/EU) (CSDR) into the EEA Agreement.
Official Journal: EEA Joint Committee Decision 17/2019 incorporating aspects of Solvency II into the EEA Agreement
Official Journal: EEA Joint Committee Decision 19/2019 incorporating aspects of the BRRD into the EEA Agreement
Official Journal: EEA Joint Committee Decision 19/2019 incorporating aspects of the CSDR into the EEA Agreement
HM Treasury
COVID-19-related amendments to CRR - HM Treasury publishes statement on the applicability of the CRR Amending Regulation - 16 July 2020
HM Treasury has published a statement on the applicability of COVID-19-related amendments to the CRR and the second Capital Requirements Regulation (EU) 2019/879 (CRR II) made by Regulation (EU) 2020/873 (CRR Amending Regulation). HM Treasury confirms that any directly applicable provision in the CRR Amending Regulation will automatically form part of retained EU law under the European Union (Withdrawal) Act 2018 (EUWA) and that it will use its powers under the Act to legislate to ensure that such provisions operate effectively in the UK at the end of the Brexit transition period.
The statement contains a list of the provisions in the CRR Amending Regulation that have applied since 27 June 2020 and will form part of retained EU law at the end of the transition period. The statement also sets out the provisions that will not apply in the UK because they become applicable after the end of the transition period, including: (i) amendments to Article 429a of the CRR, setting out the basis on which central bank exposures (CBEs) may be excluded from the calculation of the leverage ratio; and (ii) amendments to Article 92(1a) of the CRR on the requirements for own funds for global systemically important institutions (G-SIIs), which will apply from 1 January 2023.
HM Treasury states that matters relating to the leverage ratio and G-SII requirements are for the Financial Policy Committee (FPC) and the PRA to consider as part of the UK’s leverage ratio framework.
HM Treasury statement on the applicability of COVID-19-related amendments to the CRR and CRR II introduced by the CRR Amending Regulation
Webpage
UK-Singapore financial dialogue - HM Treasury and MAS publish joint communiqué - 20 July 2020
HM Treasury and the Monetary Authority of Singapore (MAS) have published a joint communiqué following the fifth UK-Singapore financial dialogue, which was held virtually and attended by senior officials from HM Treasury, the Bank of England, the FCA and the MAS.
The parties discussed a broad range of domestic and international financial market developments, as well as the following topics: (i) green finance; (ii) cyber security; (iii) the provision of cross-border data; (iv) pandemic risk financing and insurance, including regulators’ responses to COVID-19; and (v) regulatory cooperation.
The sixth UK-Singapore financial dialogue is expected to take place in London in 2021.
HM Treasury and MAS joint communiqué on the fifth UK-Singapore financial dialogue
Webpage
Prudential Regulation Authority
PRA Policy Statement PS17/20 - Securitisation: Updates to Significant Risk Transfer - July 2020
The PRA has published a Policy Statement (PS17/20) setting out its final policy with regards to its proposed updates to Supervisory Statement (SS) 9/13 ‘Securitisation: Significant Risk Transfer’. The PRA consulted on its proposed changes in its Occasional Consultation Paper (CP3/20), published in March 2020.
The PRA has decided to implement its proposals as consulted on, clarifying that non-sequential amortisation features constitute complex features in Significant Risk Transfer (SRT) transactions.
The policy changes will take effect on 22 July 2020. SS9/13 has been amended accordingly.
PRA Policy Statement PS17/20 – Securitisation: Updates to Significant Risk Transfer
Updated Supervisory Statement 9/13 ‘Securitisation: Significant Risk Transfer’
PRA Consultation Paper CP9/20 - Non-systemic UK banks: The PRA’s approach to new and growing banks - July 2020
The PRA has published a Consultation Paper (CP9/20) setting out its proposed approach to supervising new and growing non-systemic UK banks. The PRA’s proposed approach contains clarifications of the PRA’s current supervisory approach and includes proposed changes to the calculation of the PRA buffer for new banks and new expectations in relation to banks’ solvent wind-down plans.
The PRA’s proposals would also create a new supervisory statement entitled ‘Non-systemic UK Banks: The Prudential Regulation Authority’s approach to new and growing banks’. The consultation period closes on 14 October 2020.
PRA Consultation Paper CP9/20 – Non-systemic UK banks: The Prudential Regulation Authority’s approach to new and growing banks
Draft Supervisory Statement ‘Non-systemic UK Banks: The Prudential Regulation Authority’s approach to new and growing banks’
Webpage
PRA Consultation Paper CP10/20: Simplified Obligations for recovery planning - July 2020
The PRA has published a Consultation Paper (CP10/20) setting out its proposals to allow certain firms to benefit from simplified obligations for recovery planning in light of the discretion the PRA has under Article 4(1) of the BRRD. Article 4(1) permits the PRA to apply simplified obligations to firms where their failure is not expected to have a “significant negative effect on financial markets, on other institutions, on funding conditions, or on the wider economy”. Simplified obligations enable the PRA and the Bank of England to decide on the level of detail of firms’ recovery and resolution planning respectively.
The PRA’s proposals include amending SS9/17 ‘Recovery planning’ to clarify: (i) how the PRA would perform the eligibility assessment process to determine which firms are eligible for simplified obligations in respect of recovery planning; and (ii) its expectations of eligible firms’ recovery planning.
The consultation period closes on 23 October 2020, following which the PRA intends to publish a Policy Statement and notify eligible firms in the second half of 2020. The PRA intends for the proposed amendments to take effect immediately following publication of the Policy Statement.
PRA Consultation Paper CP10/20: Simplified Obligations for recovery planning
Webpage
Financial Conduct Authority
Debt advice firms - FCA publishes portfolio letter to firms - 23 July 2020
The FCA has published a portfolio letter from Caroline Gardner (Head of Department, Retail Lending Supervision at the FCA) to the Board of Directors of firms carrying on regulated activities relating to debt advice, setting out the FCA’s supervisory approach to, and expectations of, such firms in relation to the key risks which they could pose to consumers and markets. The letter also outlines the FCA’s supervisory strategy and programme of work to ensure that firms are meeting its expectations, and harms are being remedied.
The letter states that the FCA will prioritise its supervisory work in the following areas of potential harm: (i) firms’ lack of capacity to help consumers struggling with debt, including the application of ineffective processes to identify, monitor and manage risks; (ii) the provision of poor quality advice; (iii) firms’ fees and charges; (iv) non-compliant regulatory reporting and notifications; and (v) inappropriate consumer redress and prudential resources.
The FCA asks all firms to consider the issues raised in the letter and to carry out any necessary changes to their business models accordingly.
FCA portfolio letter to debt advice firms
International Banking Federation and Oliver Wyman
Technology and financial services - IBF and Oliver Wyman publish report on future regulatory challenges - July 2020
The International Banking Federation (IBF) and Oliver Wyman have published a joint report exploring how increasing digitalisation, technological innovation and the increasing involvement of technology companies in the provision of financial services provide challenges for financial regulators and prudential supervisors.
Among other things, the report makes three recommendations for the future regulation of financial services markets: (i) revising measures to adapt to increasing technological innovation in the financial services industry; (ii) strengthening the policy response to cross-sectoral regulatory issues; and (iii) extending finance-specific regulations to other industries where inconsistencies in regulation and enforcement have emerged.
IBF and Oliver Wyman joint report on the future of financial regulation in light of increasing digitalisation and innovation
Press release
New Legislation
The Co-operative and Community Benefit Societies and Credit Unions (Arrangements, Reconstructions and Administration) (Amendment) and Consequential Amendments Order 2020 (SI 2020/744)
The Co-operative and Community Benefit Societies and Credit Unions (Arrangements, Reconstructions and Administration) (Amendment) and Consequential Amendments Order 2020 (SI 2020/744) was made by HM Treasury on 16 July 2020, in exercise of the powers conferred by sections 118 and 147 of the Co-operative and Community Benefit Societies Act 2014 and section 47 of, and paragraph 92 of Schedule 4 to, the Corporate Insolvency and Governance Act 2020 (2020 Act). A memorandum containing explanatory information in respect of the Order has also been published.
Among other things, the Order applies company insolvency rescue legislation, as introduced by the 2020 Act, to certain co-operative and community benefit societies. It also makes various consequential amendments to four financial services and markets secondary instruments in consequence of the changes to the Insolvency Act 1986 by the 2020 Act. The Order entered into force on 18 July 2020.
The Co-operative and Community Benefit Societies and Credit Unions (Arrangements, Reconstructions and Administration) (Amendment) and Consequential Amendments Order 2020 (SI 2020/744)
Explanatory memorandum
Recent Cases
Case T-203/18 VQ v European Central Bank, 8 July 2020
Enforcement action fining and identifying a bank under the Single Supervisory Mechanism for breaching prudential rules – SSM Regulation (1024/2013/EU) – SSM Framework Regulation (468/2014/EU) - Capital Requirements Regulation (575/2013/EU)
The European General Court (Second Chamber, Extended Composition) has ruled that the ECB was correct in its enforcement action taken against a bank in the Single Supervisory Mechanism (SSM) under the framework set out in the SSM Regulation (1024/2013/EU) and the SSM Framework Regulation (468/2014/EU).
The applicant, VQ, a bank subject to the ECB’s prudential rules, sought an annulment of the ECB’s decision to impose a financial penalty of €1,600,000 pursuant to Article 18(1) of the SSM Regulation for having repurchased its own shares without the prior permission of the competent authority, and to publish that decision on its website. The General Court held that it was not disproportionate for the ECB to impose a financial penalty in respect of VQ, rather than a less serious disciplinary option, as Article 18 of the SSM Regulation gives the ECB discretion to decide whether an individual breach justifies the imposition of a penalty. Moreover, the publication of VQ’s identity with the financial penalty did not cause “disproportionate damage” for the purposes of Article 132(1)(b) of the SSM Framework Regulation.
Case T-203/18 VQ v European Central Bank
Case C-686/18 OC e.a. and others v Banca d’Italia and others, 16 July 2020
Legality of Italian legislation imposing a capital or asset threshold on co-operative “people’s” banks – ability to defer or limit the redemption of shares - Capital Requirements Regulation (575/2013/EU) - Commission Delegated Regulation (EU) 241/2014
The European Court of Justice (First Chamber) (ECJ) has delivered a preliminary ruling on the ability of the Italian legislature (in the light of the CRR and Commission Delegated Regulation (EU) 241/2014) to set an asset or capital threshold of €8 billion above which a co-operative "people's bank" must be converted into a company limited by shares. The Italian court also sought clarification of whether such a bank, once converted into a company limited by shares, may defer or limit redemption of shares held by a withdrawing shareholder for an unlimited period and to limit the associated amount in full or in part.
The ECJ held that Article 29 of the CRR and Article 10 of Commission Delegated Regulation (EU) 241/2014 did not prevent such a threshold from being imposed or prevent the redemption of shares from being deferred or limited as described.
Case C-686/18 OC e.a. and others v Banca d’Italia
Case C-452/18 XZ v Ibercaja Banco SA, 9 July 2020
Waiver of consumer’s rights – ‘floor’ interest rate terms in mortgage loan agreements - Unfair Contract Terms Directive (93/13/ECC)
The ECJ (Fourth Chamber) has delivered a preliminary ruling on the correct interpretation of Articles 3, 4, 5 and 6 of the Unfair Contract Terms Directive (93/13/ECC) (UCTD) on the validity of a waiver of a consumer’s accrued rights in respect of an unfair term in a mortgage agreement.
In 2014, following a decision by the Spanish Supreme Court that ‘floor’ interest rate terms in mortgages agreements are void unless sufficiently clear and transparent, the bank began renegotiating such terms in its existing mortgage agreements. The consumer in question signed an agreement amending their mortgage agreement to introduce a new, lower floor rate and waive any accrued rights of action they might have in respect of both the historic floor interest rate and any new floor interest rate terms.
The ECJ held that a consumer may waive their accrued rights in respect of an unfair floor interest rate term in a mortgage agreement, provided they do so freely and having been fully informed of the rights that they are waiving. However, a waiver of future rights in respect of potentially unfair terms would not be permitted; such a waiver would run counter to mandatory EU consumer protection rules.
Case C-452/18 XZ v Ibercaja Banco SA
Please see the General section for an item on an FCA statement highlighting the difficulties caused by firms using cheques in light of COVID-19.
