The Bank of England has announced that it will discontinue its three-month Contingent Term Repo Facility at the end of May 2020, with the final operation scheduled to take place on May 28, 2020. The BoE’s one-month CTRF operations will continue on a weekly basis until at least June 26, 2020. The BoE has also said that it will reintroduce the operations if necessary. 
 
The CTRF was established by the BoE in March 2020, at the outset of the COVID-19 outbreak, allowing financial market participants to borrow central bank reserves in exchange for less liquid assets.
 
View the BoE's market notice on amendments to the CTRF.

The U.K. Prudential Regulation Authority has published a new statement on the application of regulatory capital and IFRS 9 requirements to payment holidays granted or extended to address COVID-19. The statement follows the announcements made by the PRA, the U.K. Financial Conduct Authority and the U.K. Financial Reporting Council in March 2020 on financial reporting and audit requirements in light of COVID-19. Those announcements included a letter from the PRA to banks on the application of IFRS 9 (including expected credit loss accounting) to loan arrangements during the pandemic.

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The U.K. Financial Conduct Authority has published two consultations on its draft guidance for firms on mortgages and safeguarding customers’ funds during the COVID-19 pandemic.
 
The first consultation relates to the FCA’s proposed guidance on how mortgage lenders should treat customers coming to the end of a payment holiday or those yet to request one. The timeframe for customers who have not yet benefited from a payment holiday to apply for one will be extended to October 31, 2020. The current ban on house repossessions will also be extended to October 31, 2020.

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The U.K. Government has published the U.K. Corporate Governance and Insolvency Bill. The Bill amends aspects of insolvency and company law to assist firms struggling to cope with the effects of the COVID-19 pandemic. The measures include:
 

• A new moratorium giving companies breathing space from creditors while they investigate rescue options;
• A prohibition on contractual termination upon insolvency clauses, preventing suppliers from refusing to supply goods while a company is going through a rescue process;
• A temporary removal of liability for wrongful trading for company directors who try to keep their businesses operating through the pandemic;
• A temporary prohibition on the filing of statutory demands and winding up petitions by creditors; and
• Temporary permission for companies to hold closed Annual General Meetings.

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The European Securities and Markets Authority has published a statement calling for transparency in the half-year financial reports of EU-listed issuers. The statement focuses on interim financial statements that need to be prepared according to IFRS standards and on interim management reports for 2020 half-yearly reporting periods. However, the statement is also relevant to the reporting of financial information in other interim periods. ESMA highlights that issuers must provide updated and useful information that covers the current and expected impact of the coronavirus pandemic on their financial position, performance and cash-flows. In addition, issuers should identify the principal risks and uncertainties to which they are exposed.

View ESMA's statement.

The U.K. Prudential Regulation Authority has published a Policy Statement on its approach to implementing the European Banking Authority's Technical Standards and Guidelines on Probability of Default estimation, Loss Given Default estimation and the treatment of defaulted exposures in the Internal Ratings Based approach to credit risk. The EBA's regulatory products are designed to address concerns about the variability of own funds requirements arising from the internal models that firms use to calculate their minimum credit risk capital requirements under the Capital Requirements Regulation. The Policy Statement is relevant to U.K. banks, building societies and PRA-designated U.K. investment firms.

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The U.K. Government intends to exempt financial services firms from certain provisions of the new U.K. Corporate Governance and Insolvency Bill. The Bill, announced on March 28, 2020, will amend aspects of the U.K. insolvency regime (as set out under the Insolvency Act 1986) in light of the financial difficulties faced by many businesses as a result of the COVID-19 pandemic. The Bill also includes provisions for companies’ annual general meetings and filing requirements during the COVID-19 crisis.

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The European Systemic Risk Board has established five priority areas on which it intends to take action to combat the impact of COVID-19 on the EU financial system. In determining its actions, the ESRB hopes to ensure an effective response to the pandemic across the EU that prevents individual Member State actions from negatively impacting the EU Single Market and to take advantage of flexibility in regulatory standards to support financial institutions in providing financial services and liquidity.

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The Bank for International Settlements has published a report on financial crime during the COVID-19 pandemic. The Report provides an overview of the increase in financial crime observed since the COVID-19 outbreak, which includes an increase in cyber threats, greater misuse of online financial services and virtual assets to move illicit funds and possible corruption associated with government stimulus funds. The Report also describes the cyber resilience measures proposed by national and international agencies and the AML actions taken by supervisory bodies, including the issuance of public statements to raise awareness of COVID-19-related AML risks, provision of guidance on the application of existing AML/CTF frameworks and coordination with the financial sector for the reporting of COVID-19-related fraud.

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The European Securities and Markets Authority has published a statement confirming its support for the European Systemic Risk Board's Recommendation on tackling the implications of market illiquidity for asset managers with exposures to corporate debt and real estate. In accordance with the ESRB's Recommendation, ESMA intends to coordinate with Member State national regulators to engage closely with these asset managers. The supervisory engagement ties in with ESMA's common supervisory action, announced in January 2020, on liquidity risk management by managers of Undertakings for the Collective Investment in Transferable Securities.

View ESMA's statement on fund managers' liquidity risk management.

View details of the ESRB's Recommendation.

View details of ESMA's common supervisory action on liquidity risk management for UCITS.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The U.K. Financial Conduct Authority has announced a series of updates to the Working Group on Sterling Risk-Free Reference Rates’ proposed implementation of LIBOR reforms. In March 2020, the RFRWG published a roadmap for the discontinuation of new sterling LIBOR lending by the end of Q3 2020. The FCA, Bank of England and RFRWG now acknowledge that, in light of the COVID-19 pandemic, it will no longer be feasible to transition away from LIBOR across all sterling LIBOR-linked loans by this proposed deadline.

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The U.K. Financial Conduct Authority has published guidance on how firms should handle post and paper documents during COVID-19. The FCA expects firms to continue to comply with requirements for post and paper-based processes and, where this is not possible, firms should notify the FCA. The FCA also expects firms to contact customers who do not use online services in a timely manner and should be able to demonstrate any steps they have taken to mitigate the impact of any non-compliance with usual post and paper-based processes.

Firms should also ask customers who have sent cheques via post that have not yet been processed to contact the firm. The firm should consider whether the cheque relates to client money under the FCA’s Client Assets Sourcebook regime, whether they are able to provide the services without cashing the cheque and, if so, whether their intended actions are in compliance with the FCA Client Assets Sourcebook.

View the FCA's statement on post and paper documents.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The Bank of England’s Financial Policy Committee and Monetary Policy Committee have published reports focusing on the impact of COVID-19 on the U.K. economy and banking sector, together with the minutes of their May Committee meetings and a transcript of the BoE’s joint FPC and MPC press conference, discussing the findings of the Committee reports.

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The U.K. Financial Conduct Authority has issued guidance on financial crime controls and information security for financial services firms during COVID-19. The FCA notes the increase in cyber-crime during the COVID-19 pandemic, the risks of which may be magnified by operational disruptions arising from working from home arrangements. Firms are expected to be proactive in managing the increased risks during this period, including being vigilant about the potential increase in cyber risks, ensuring they maintain appropriate governance and oversight arrangements, reviewing the impact of COVID-19 on their information security defenses and ensuring that general notification requirements are followed and significant cyber incidents are reported.

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The U.K. Financial Conduct Authority has extended the maximum period for which FCA solo-regulated firms are permitted to arrange cover for a Senior Manager without seeking the FCA's approval from 12 to 36 weeks, within a consecutive 12-month period. Firms will be able to reallocate an absent Senior Manager's prescribed responsibilities for up to a 36-week period via an application for a modification by consent of the FCA's standard 12-week rule. The modification by consent will apply from the date of the firm's application until April 30, 2021. The FCA is yet to issue any further guidance regarding the application of the 12-week rule to U.K. dual-regulated firms.

View the FCA's modification by consent to the 12-week rule.

The European Securities and Markets Authority has published a statement reminding firms of their MiFID II conduct of business obligations in light of a significant increase in investment accounts opened by retail clients, together with a surge in retail clients' trading activities.

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HM Treasury's Bounce Back Loan Scheme has launched today. The scheme provides government guarantees for loans between £2,000 to £50,000 and will enable small businesses to apply for loans quickly and easily. The loans will also be subject to a flat interest rate of 2.5% and firms that have already taken out a Coronavirus Business Interruption Loan of £50,000 are entitled to apply for it to be switched to the BBLS. HM Treasury has also published a Dear CEO letter addressed to accredited lenders describing the pricing and regulation of the BBLS and the interaction between the BBLS and the CBILS. Loans of £25,000 or less made under the BBLS will also fall outside the regulatory perimeter for the purposes of the Consumer Credit Act 1974 and the Financial Services and Markets Act 2000.

View HM Treasury's announcement on the BBLS.

View HMT's Dear CEO letter on BBLS.

View details of the regulatory perimeter exemption for the BBLS.

The U.K. Prudential Regulation Authority has published a statement on credit risk mitigation eligibility and the leverage ratio treatment of loans made under HM Treasury's Bounce Back Loan Scheme and a separate modification by consent of the exclusion of loans under the BBLS from the calculation of the total exposure measure of the leverage ratio.

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The European Supervisory Authorities have published updated joint draft Regulatory Technical Standards amending the existing EU risk mitigation techniques for uncleared OTC derivatives. In December 2019, the ESAs published a draft RTS to amend existing bilateral margin requirements made under the European Market Infrastructure Regulation in line with certain clarifications made to the related international framework by the Basel Committee on Banking Supervision and the International Organization of Securities Commissions. These updated draft RTS include all those amendments and also delay the upcoming bilateral margin requirements to bring the EU framework in line with the global timeline. In response to the coronavirus outbreak, the Basel Committee announced in April 2020, a one-year deferral for the implementation of the final two phases of the joint Basel Committee and International Organization of Securities Commissions' framework for non-centrally cleared derivatives margin requirements.

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The U.K. Financial Conduct Authority has announced a new digital sandbox pilot program, which will provide regulatory support for innovative firms whose business plan addresses issues arising from the coronavirus pandemic. The FCA intends to open the sandbox for applications in summer and, in the meantime, welcomes any expressions of interest from interested innovative firms. The FCA had been planning a digital sandbox before the pandemic, but is fast-tracking the process in light of the challenges facing firms and how the sandbox might assist them.

View the FCA's announcement.

The Financial Action Task Force has published a report on financial crime (including money laundering and terrorism financing activities) during COVID-19, identifying challenges, good practices and policy responses to the emerging threats and vulnerabilities.

The increased threats identified include fraud from criminals attempting to profit from the pandemic, a spike in cyber crime, particularly phishing emails and spam campaigns and a corresponding impact on other predicate crimes including human trafficking, exploitation of workers, online child exploitation and organized property crime. In conjunction, confinement and social distancing measures designed to combat COVID-19 are impacting government and private sector capacity to implement AML and CTF obligations.

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The Bank of England and U.K. Prudential Regulation Authority have issued a statement on changes to the resolution measures applicable to the major U.K. banks and building societies, designed to ease the operational burden on firms in the wake of COVID-19.

The dates by which firms must submit their first reports describing their preparations for resolution, and publish summaries of those reports, under the BoE and PRA’s new Resolvability Assessment Framework have been extended by one year. The first reports should be submitted to the PRA by October 2021 and public disclosures should be made by June 2022.

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HM Treasury has published the Financial Services and Markets Act 2000 (Regulated Activities) (Coronavirus) (Amendment) Order 2020, exempting certain loans made under the U.K. Government's Bounce Back Loan Scheme from regulation under the U.K. financial regulatory regime. The Order applies to loans of £25,000 or less made under the BBLS by commercial lenders to sole traders, unincorporated associations and partnerships of four people. These loans will be classed as exempt credit agreements and will therefore largely not be subject to the provisions of the Consumer Credit Act 1974. 

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The U.K. Financial Conduct Authority has granted firms an additional six months to implement strong customer authentication for e-commerce, extending the deadline from March 14, 2021 to September 14, 2021. The forbearance has been granted in light of the exceptional circumstances arising from COVID-19, in a bid to minimize disruption to consumers and merchants.

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The European Central Bank has announced a series of modifications to its targeted longer-term refinancing operations (referred to as TLTRO III) to facilitate ongoing access of firms and households to bank credit. TLTRO III is the latest in the series of Eurosystem refinancing operations that provide financing to Eurozone credit institutions.
 

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The U.K. Prudential Regulation Authority and the U.K. Financial Conduct Authority have published guidance for firms on the implications of HM Treasury's amendments to the U.K. Coronavirus Business Interruption Loan Scheme and Coronavirus Large Business Interruption Loan Scheme and the introduction of the Bounce Back Loan Scheme.

HM Treasury has announced the new BBLS which will run alongside the existing CBILS and CLBILS, providing government guarantees for loans to small businesses of between £2,000 and £50,000. The minimum threshold for CBILS loans will be increased to £50,001, and firms with existing CBILS loans of £50,000 or less will be entitled to switch their facility to the BBLS. The BBLS will launch for applications from May 4, 2020.

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The European Banking Authority has published guidance on its supervisory flexibility for certain aspects of the European bank prudential regulatory framework, in light of the COVID-19 pandemic.

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The U.K. Prudential Regulation Authority has published a Q&A guide on how banks should use their capital and liquidity buffers during the COVID-19 crisis. The PRA and Financial Policy Committee have stressed the important role that banks must play in providing liquidity to the economy in the wake of the pandemic, using all tools at their disposal, including the buffers built up in the years since the 2007-2009 financial crisis.

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The U.K. Financial Conduct Authority has published a statement on its expectations for wet-ink signatures in light of the coronavirus pandemic. The FCA confirms that FCA rules do not require wet-ink signatures for agreements and do not prevent the use of electronic signatures either. However, the FCA stresses the validity of electronic signatures is a legal matter, for which firms should seek legal advice, if appropriate.

The FCA also states that firms may use electronic signatures in submitting forms.

View the FCA's statement on wet-ink signatures.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The U.K. Financial Conduct Authority has published a statement on its intended approach to prudential regulation of FCA solo-regulated firms during the COVID-19 pandemic. Firms are expected to plan ahead and prudently manage their financial resources. Firms that have been set capital buffers are permitted to use them to support the continuation of their activities, but should contact the FCA if they intend to draw down a buffer. Firms should also maintain up-to-date wind-down plans taking account of the impact of COVID-19 and should contact the FCA if they are concerned about their ability to meet debts as they fall due or their wind-down plans identify material execution risks. Boards should be satisfied that any discretionary distributions of capital to fund share buy-backs, dividends, or upstream cash are prudent.
 
View the FCA's statement on financial resilience for solo-regulated firms.

The European Central Bank has announced its decision to temporarily reduce capital requirements for market risk in response to high levels of volatility arising from the COVID-19 pandemic. The reduction will be effected via the reduction of the qualitative market risk multiplier, a supervisory measure that is set by regulators and used to compensate for underestimation of market risk capital requirements. The ECB's decision will be reviewed after six months.
 
View the ECB's announcement on capital requirements relief for market risk.

The G20 finance ministers and central bank governors have published an Action Plan for the international response to the COVID-19 pandemic. The Action Plan covers the healthcare, economic and fiscal responses that G20 members have agreed to undertake, as well as measures to ensure a return to a strong and sustainable global economy, the provision of support to countries in need and the learning of lessons in preparation for future crises.

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The European Central Bank, Banking Supervision has published a letter addressed to the significant Eurozone banks that it directly prudentially supervises under the Single Supervisory Mechanism. The ECB, Banking Supervision, expresses its support of the EBA's statement dated March 31, 2020 on supervisory reporting and Pillar 3 disclosures. In line with the EBA's statement, the ECB: (i) confirms that significant Eurozone banks may delay by one month the submission of supervisory data for remittance dates between March 2020 and May 2020; (ii) excludes information on the liquidity coverage ratio; and (iii) is allowing firms an additional two months to submit information on funding plans.

The ECB recommends that Eurozone national regulators should apply the same delays to the smaller Eurozone banks.

View the ECB's letter to significant banks.

View details of the EBA's statement on supervisory reporting and Pillar 3 disclosures.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The Financial Stability Board has published a report to the G20 on the financial stability implications and policy measures taken in response to the coronavirus pandemic. The report provides an overview of the impact on financial stability of the outbreak and describes the policy actions taken by FSB member jurisdictions. The FSB confirms that it is monitoring financial resilience, focusing on the ability of:

• financial institutions and markets to channel funds to the real economy;
• market participants to obtain U.S. dollar funding, particularly in emerging markets;
• financial intermediaries to manage liquidity risk; and
• market participants and financial market infrastructures, such as CCPs, to manage evolving counterparty risks.

The report also sets out how the FSB is supporting international cooperation and coordination on the COVID-19 response by: (i) information sharing; (ii) conducting financial stability risk assessments; and (iii) assisting with coordinating responses on policy issues.

View the FSB's report to the G20 on the COVID-19 response.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The U.K. Financial Conduct Authority has published a Dear CEO letter to U.K. regulated banks on lending to small businesses. In the letter, the interim Chief Executive, Christopher Woolard, reminds banks about the importance of ensuring that the benefits of the Government's Coronavirus Business Interruption Loan Scheme are passed to the businesses and consumers that need it. The FCA confirms that it and the PRA are monitoring the level of lending to businesses.

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The Financial Stability Board has published a letter from Randal K. Quarles, the FSB Chair, to G20 Finance Ministers and Central Bank Governors on the response to the coronavirus pandemic. The letter highlights that the financial sector needs to respond to a "twin challenge": the increased demand for credit throughout the global economy and the uncertainty around the value of assets. The letter describes how the FSB and its member jurisdictions have responded to the pandemic to support local and global market functioning, discussing in particular, the steps taken to maintaining financial stability and supporting the real economy during the COVID-19 crisis. The letter also outlines the work to promote a global financial system that supports a strong recovery, including the FSB's prioritizing of certain areas, namely non-bank financial intermediation, the orderly transition away from LIBOR, utilizing technological innovation to assist in cybersecurity and promoting efficient and resilient cross-border payments.

View the FSB's letter.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The European Securities and Markets Authority has issued a public statement announcing the delay of the publication dates of the annual transparency calculations for non-equity instruments. ESMA's statement is made in response to the impact of the coronavirus. The Markets in Financial Instruments Directive and Markets in Financial Instruments Regulation, which became effective on January 3, 2018, introduced pre- and post-trade transparency requirements for equity and non-equity financial instruments. ESMA is postponing the publication of the annual transparency calculation for derivatives, exchange traded commodities, exchange traded notes, emission allowances and structured finance products from April 30, 2020 to July 15, 2020 and their application from June 1, 2020 to September 15, 2020. The transitional transparency calculations will continue to apply until September 14, 2020 (inclusive). The publication and application of the annual transparency calculations for bonds remain unchanged. The new thresholds will be applicable from June 1, 2020.

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The European Securities and Markets Authority has announced its expectation that national regulators should, where possible, deprioritize supervisory action against certain fund managers for failure to comply with periodic financial reporting deadlines for funds they manage for the periods ending from December 31, 2019 to April 30, 2020 (inclusive). The fund managers covered by ESMA’s statement are: (i) undertakings for the collective investment in transferable securities (UCITS) management companies; (ii) self-managed UCITS investment companies; (iii) authorized alternative investment fund managers; (iv) non-EU AIFMs marketing AIFs; (v) European Venture Capital Fund managers; and (vi) European Social Entrepreneurship managers.

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The U.K. Prudential Regulation Authority has announced a series of amendments to regulatory reporting and disclosure requirements applicable to U.K. banks, building societies, designated investment firms and credit unions, in light of the global COVID-19 pandemic. The PRA’s changes follow recent statements and recommendations made by the European Banking Authority, providing clarity on measures to mitigate the impact of COVID-19 on the EU banking sector.

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The U.K. Prudential Regulation Authority has published its Business Plan for 2020/2021, which sets out its strategic goals for the next 12 months and its work plan to deliver them. The PRA has had to tailor its intended Business Plan to take account of the impact of the COVID-19 pandemic. In particular, it has elected to cancel its 2020 annual cyclical scenario stress tests, delay the publication of the results of the 2019 biennial exploratory scenario, postpone less critical aspects of its supervisory program for individual firms and extend consultation periods and implementation timeframes for new initiatives where possible.

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The European Securities and Markets Authority has issued a public statement asking national regulators across the EU not to prioritize supervisory actions against interest rate benchmark administrators and contributors for failing to comply with the external audit requirements under the Benchmark Regulation, where those audits are carried out by September 30, 2020. The EU Benchmark Regulation requires an interest rate benchmark administrator to have an external audit conducted of its compliance with the benchmark methodology and Benchmark Regulation. Contributors to interest rate benchmarks are required to have an external audit conducted of their input data and compliance with the Benchmark Regulation. ESMA is granting the regulatory forbearance in response to the impact of COVID-19. ESMA states that administrators and contributors that anticipate a delay to the required audits should inform their nation regulator.

View ESMA's statement.

Details of other regulatory responses to COVID-19 are available on our COVID-19 Research Center.

The U.K. Prudential Regulation Authority has announced two further measures in response to the coronavirus outbreak. The first is the PRA's decision to maintain the systemic risk buffer rates at the rate set in December 2019. The rates determine the amount of additional regulatory capital that must be held by "systemic risk buffer institutions" (i.e. U.K. financial institutions deemed to be systemically important). In scope firms are the so-called "ring-fenced bodies" within the meaning in the Financial Services and Markets Act 2000 and include banks and large building societies holding more than £25bn in deposits. The buffer applicable to each institution is intended to reflect the relative costs to the U.K. economy if the institution in question were to fall into distress. In December 2019, the PRA maintained the rates that had first been set in May 2019. The SRB rates will be re-assessed in December 2021 and the decision taken then will take effect in January 2023.

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The U.K. Financial Conduct Authority has published its Business Plan for 2020/2021, which sets out its five key priorities for the next one to three years.

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The European Commission has launched a consultation on a retail payments strategy for the EU. The Commission's final strategy will be published in Q3 2020 alongside the new digital finance strategy, on which the Commission launched a consultation on the same day. The consultation closes on June 26, 2020.

The Commission states that the RPS will be a key to reinforcing the international role of the euro, strengthening Europe's influence and enhancing its economic autonomy. In addition, the Commission notes that safe and efficient payment systems and services will assist the EU in tackling emergencies, such as the coronavirus outbreak.

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The Basel Committee on Banking Supervision has announced a series of measures designed to reduce the impact of COVID-19 on the global banking sector. The latest measures are designed to facilitate bank lending to the real economy and boost banks’ operational capacity to the financial strain of COVID-19. They follow the extension to Basel III implementation deadlines announced by the Group of Central Bank Governors and Heads of Supervision on March 27, 2020.

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The U.K. Financial Conduct Authority has published guidance for solo-regulated firms on adherence to the Senior Managers and Certification Regime in light of COVID-19. The FCA has separately issued joint Guidance with the Prudential Regulation Authority on the SM&CR for dual-regulated firms.

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HM Treasury has announced further funding to support businesses during COVID-19. The actions include extending the Coronavirus Business Interruption Loan Scheme to make all small businesses affected by COVID-19 eligible for funding, as opposed to just those unable to secure regular commercial financing. Lenders will also no longer be permitted to seek personal guarantees for loans under £250,000. The government has also announced the introduction of the new Coronavirus Large Business Interruption Loan Scheme, which will make government-backed loans of up to £25 million available to firms with an annual turnover of between £45 million and £500 million.
 
The funding schemes will not be available to banks, insurers or building societies. Further details of all of the government's funding schemes can be found on the government's website.
 
View the government's announcement on COVID-19 support measures.
 
View the Government's COVID-19 support packages.

The U.K. Financial Conduct Authority and Prudential Regulation Authority have published joint guidance for dual-regulated firms on adherence to the Senior Managers and Certification Regime in light of COVID-19. The U.K. regulators intend to be flexible in enforcing SM&CR requirements given the disruption to personnel and operations triggered by the pandemic. The FCA has issued separate guidance for solo-regulated firms subject to the SM&CR.

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The European Commission has launched a consultation on a new digital finance strategy and FinTech action plan for Europe. The Commission states that although it is prioritizing fighting the coronavirus pandemic, it has decided not to delay this work because the digital finance can help to tackle issues arising as a result of the coronavirus pandemic. The Commission's final strategy, due to be published in Q3 2020, will set out the focus FinTech policy areas for the next five years. The consultation closes on June 26, 2020.

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The Financial Stability Board has announced its coordinated actions with FSB members to support the real economy and maintain financial stability in the wake of COVID-19. Key actions include:

• Information sharing – FSB members are sharing information on the actions taken to deal with COVID-19, which include lending and liquidity support, market functioning support and measures to support business continuity of both financial institutions and regulators;

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