Bank of England Revises Criteria for Monthly Form BT Reporting by Deposit-Takers

Key Takeaways

• The Bank of England is changing the criteria that determine which firms must submit Form BT monthly.
• Monthly submission will generally apply only to firms that also file specified monthly Money and Credit returns (Forms BE, BN, GT or ER), and some current monthly filers will move to quarterly.
• Compliance teams should confirm their status once the Bank contacts them, because the effective dates and notice periods have not yet been published.

Deep Dive

The Bank of England is changing the criteria that determine which firms must submit Form BT monthly. Monthly submission will generally apply only to firms that also file specified monthly Money and Credit returns (Forms BE, BN, GT or ER), and some current monthly filers will move to quarterly. Compliance teams should confirm their status once the Bank contacts them, because the effective dates and notice periods have not yet been published.

The practical effect depends on the firm. Some firms currently reporting monthly will move to quarterly and may see a lower reporting burden. Other firms may stay on monthly reporting because of their Money and Credit return obligations. The Bank also keeps discretion to require monthly Form BT from any firm, even one that files none of the listed forms. Quarterly status is therefore a general rule, not a guarantee, and firms should not assume a move to quarterly reporting is permanent.

The notice sets no effective date or deadline. The Bank will contact affected firms individually to confirm any change and the date from which it applies. It will also publish updated reporting thresholds guidance on its website, including the notice periods for changes in reporting requirements. The notice period for removing a monthly requirement may be shorter than the period for introducing one. Teams should therefore be ready for a short lead time when moving to quarterly reporting, and should not assume a long runway if monthly reporting is imposed.

Recommended actions:
- Identify which of Forms BE, BN, GT and ER the firm currently submits, and map this against current Form BT frequency.
- Monitor the Bank's website for the updated thresholds guidance, and watch for direct correspondence, including in regulatory mailboxes.
- Keep monthly processes, controls and staffing in place until the Bank confirms the change in writing.
- Update regulatory reporting calendars, procedures, ownership and sign-off arrangements once the effective date is known.
- Confirm that the firm's contact details are current on the Statistical Notices circulation list.
- Direct queries to the Money and Credit Group at DSDMCG@bankofengland.co.uk.

The risk impact is mostly operational. The main exposures are missed or late submissions caused by missed communications, by stopping monthly reporting too early, or by misreading the Bank's discretion. Reduced frequency may lower workload and cost, but firms should keep the data quality and reconciliation controls that support the underlying statistical returns. Overall impact is low to moderate and varies by firm.

Source: Bank of England