Nationwide desired to get Government attention on a new form of capital raising instrument to replace PIBS. Our role was to ensure that the sensitive dialogue with HMT and HMRC was focused on a solution that the Government thought sensible, and helped Nationwide achieve its objective. We advised on the implications of this move as the parallel debate on bank capital requirements from the Vickers report impacted upon specific HMT, TSC and regulatory thinking.
It was vital to separate the ‘business as usual’ activity strand with HMT from specific dialogue on what became CCDS. We were involved in the strategy behind this, with the executive team, and took part in HMT calls with Ministers where the idea for how CCDS could be achieved took fruition. We also advised on the implementation of a plan once Parliamentary approval was given, to announce the scheme details. Approval for CCDS was achieved with no external awareness, but internal approval and alignment across HMT, HMRC and regulatory audiences, a key outcome for the business.
The plan for announcement came at a time when other corporate activities, including Q3 results, were happening so it was important to get exposure for this exclusive of those. This was achieved with a major piece from Robert Peston extolling the unique nature of this new instrument.
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