Ian Tyler argues that effective regulation requires accountability, proportionality, and challenge. Drawing on decades of experience across treasury, capital management, consulting, and regulatory engagement, he examines how regulatory frameworks have evo
For Ian Tyler, the journey from risk
practitioner to regulatory commentator has revealed both the strengths and
weaknesses of modern banking supervision.
The Senior Advisor at Financial
Markets Consulting & Resourcing has spent more than three decades working
across treasury, balance sheet management, capital planning, consulting, and
regulatory engagement.
That breadth of experience has given
him a unique perspective on how regulation has evolved since the financial
crisis and where he believes improvements are still needed.
Reflecting on his career, Tyler
described treasury as the function that sits at the center of the bank,
requiring practitioners to understand regulation, accounting, markets,
products, capital, liquidity, and risk simultaneously.
“You have to understand the
regulation. You have to understand the accounting. You have to understand
markets because markets have limits,” he explained. The role also demands a
detailed understanding of the institution itself and how risks interact across
the balance sheet.
His experiences during the financial
crisis shaped many of his current views. Having taken responsibility for
capital management at Royal Bank of Scotland in early 2008, Tyler witnessed
firsthand the pressures created by deteriorating market conditions, regulatory
changes, and acquisition-related challenges.
Looking back, he highlighted how
regulatory decisions sometimes amplified stress during periods of uncertainty.
In particular, he pointed to examples where capital requirements increased just
as institutions were already under pressure.
“The regulator communicated to the
board that they wanted to move the goalposts,” he recalled, describing how
higher capital expectations arrived precisely when market conditions were
worsening.
Despite his support for most
post-crisis reforms, Tyler believes some regulatory measures have become overly
restrictive or insufficiently targeted.
He cited ring-fencing as an example
of a policy that has imposed significant costs while delivering limited
additional benefit. More broadly, he questioned whether certain regulatory
frameworks adequately support competition and growth within the banking sector.
One area of concern is the UK's
approach to the countercyclical capital buffer. Tyler argued that the original
Basel intention was for the buffer to be deployed when economies showed signs
of overheating.
