Banks Won’t Wait to See What Brexit Deal the U.K. Can Getby
Executives said to assume U.K. will lose passporting rights
Firms need the two-year period to set up elsewhere in Europe
Big investment banks with their European headquarters in London will start the process of moving jobs from the U.K. within weeks of the government triggering Brexit, a faster time line than their public messages of patience would imply, according to people briefed on the plans being drawn up by four of the biggest firms.
Dismayed by the lack of a clear plan to protect the U.K.’s status as a global financial hub, executives are planning for the worst -- that they will lose the right to sell services freely around the European Union from the City, said the people, who asked not to be identified because the plans are private. Facing a long process with potential waits for regulatory approvals before workers can pack their bags, banks want to start quickly in order to have new or expanded offices set up in Europe before the end of the two-year Brexit negotiation period.
"This year is all about understanding potential scenarios, your options, and what your contingency plans are," said Andrew Gray, head of Brexit for U.K. financial services at PwC, which is advising banks on how best to respond to Brexit. "Some plans will take time to execute, and firms can’t afford to wait until Jan. 1, 2019, and risk not being able to do business."
While U.K. Prime Minister Theresa May has said she will fight for the City of London to retain its passporting rights, bankers and lawyers say she faces an uphill battle trying to win concessions from EU partners still smarting from the outcome of the June 23 vote. Bank executives are privately discouraged that seven weeks after the referendum, the ministers in charge of negotiating the best deal for the U.K. believe they can retain the benefits of being in the single market without accepting the free movement of EU citizens, the people said.
Banks are in a race against each other to secure the best office space and accommodation for the thousands of workers they would eventually move from the U.K., given the limited number of suitable destinations in those cities. They also want to be first in line with the local regulators, who will likely struggle to cope with an influx of investment banks asking permission to set up shop.
An isolated London would be a particularly acute problem for Wall Street banks given the significant revenue they generate in from EU clients. Eighty-seven percent of U.S. investment banks’ EU staff are located in the U.K., which is also home to 78 percent of the region’s capital markets activity, according to think tank New Financial.
Before the referendum, JPMorgan Chase & Co. Chief Executive Officer Jamie Dimon said he would relocate as many as 4,000 employees to the continent after Brexit. Morgan Stanley may move as many as 1,000 employees out of the U.K., while Goldman Sachs Group Inc. and Citigroup Inc. indicated they would also shift people abroad. European banks including HSBC Holdings Plc and Deutsche Bank AG said they may have to move people or activities to France and Germany.
Bank bosses have struck a softer note in public since the vote, saying that they would wait and see how the U.K.’s negotiations with the EU panned out before making any decisions on the number of employees or timing.
To be sure, beginning the process won’t mean employees would immediately start moving, the people said. The first steps would involve setting up a new legal entity structure with a home base inside the EU, applying to the local regulator for a banking license and getting approval for the internal models they use to calculate their capital requirements, a process which can take years on its own.
The banks would need to coordinate with one another on their moving plans to avoid any logjam with local regulators, said one of the people. Those discussions could be facilitated by one of the industry lobby groups such as TheCityUK, the person said.
Banks could yet delay their departure from the U.K. if the British government was able to secure a lengthy transition period from the current rules to whatever fresh terms of trade are agreed with the EU, said the people. That would need to be agreed before the U.K. actually triggered Article 50, which is expected to happen in 2017.
U.K. ministers may decide to wait until after France and Germany hold national elections next year before pulling the trigger on Brexit, three of the people said.
Britain’s exit from the EU is going to be a long, drawn out process, said Rupert Harrison, a former adviser to then Chancellor of the Exchequer George Osborne who now works at BlackRock Inc. That will probably result in the U.K. government trading away banks’ passporting rights in return for ongoing access to the single market for other parts of the economy, he said.
"If banks are moving some of these jobs, I think that is entirely a rational thing to do for them," Harrison said in interview with Bloomberg TV’s Francine Lacqua. "It is very hard to see a way to thread through this that retains these single-market access roles."