I’m John Coley, I’m head of EMEA for our risk consulting practice at Norton Rose Fulbright. Today I wanted to talk to you about the FCA’s business plan, which has just been released for 2020/21.
Unsurprisingly, the plan is really dominated by the corona virus and its ongoing impacts across the world and also of course on financial services firms and their customers. It is clear that the FCA recognises the impact of the virus is still evolving all the time and essentially what this means is that the FCA may need to give an update to the plan in due course, if it deems necessary.
I wanted to talk to you today firstly about the types of things covered in the plan, and then secondly about areas that we think it’s important for firms to consider in terms of trying to help them best respond to it.
Firstly the FCA identifies five key priorities. Firstly transforming itself and how it works and regulates and then moving on to external priorities including effective consumer investment decisions, ensuring consumer credit works well, making payments safe and accessible, and also delivering fair value in the digital age.
The FCA then moves on to its cross-cutting work which includes EU withdrawal, climate change, innovation and technology, Operational resilience, financial crime and culture.
Lastly there is the FCA’s sector work. A couple of points to bring out here is libel is still referenced as ending at the end of 2021, SM&CR and effective governance remain a key theme, and also, of course, Operational resilience, financial crime and consumer’s access to products and services that meet their needs.
So what does this all mean and what should firms be thinking about? As the virus develops, there will be a myriad of challenges but no doubt you’re all working very, very hard to meet. From top-down perspective, I think there are some key areas to bear in mind. Firstly ensuring over time that you have a clear and consistent governance arrangements and meetings, and these meet regularly as the crisis develops so you can be agile and flex these where appropriate. Also regularly reviewing your response plans so that customer feedback and evolving areas of challenge can be factored in. Having a consistent protocol in place for evidencing key decisions made and how, when and where to escalate matters is critically important given SM&CR, and the fact that regulators will come back to review these in due course. Being clear and consistent with public communication and lastly keeping fairness under review, because of course, at the moment, everybody wants to do the right thing by their customers, but being mindful of how this develops and whether detriment could in fact be created if customers are being given too much forbearance, for example.
I hope you found this interesting, and if you have any queries or questions please do get in touch. Thank you.