Ian Tyler examines the balance between effective regulation, financial stability, and accountability in modern banking supervision. Drawing on more than three decades of experience in treasury, capital management, and regulatory engagement, he argues that
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 postcrisis 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. Instead, he believes the UK
has effectively embedded the buffer more permanently than many other major
jurisdictions.
