Consultancy Training Coaching Resource

Temple Risk Regulation



June 2013


Keeping up with the Jones’s?

One of the great benefits of consultancy work is


having the opportunity to see how very different


firms in different sectors tackle the same regulatory




Many of the solutions are transferable and firms


take their own spin on how to tailor approaches that


work for them. However, management practices


keep on moving and it’s arguable that once the


regulator has seen a particular solution well


executed in one firm it sets the bar higher for




In a sense the regulator’s expectations are naturally


creeping up all the time and FCA’s deliberate


raising of the bar can only accelerate this.

Investing in People and



The ideal business response is to have capable


well-motivated employees who continuously


develop their skills in an environment where the firm


also invests in suitable IT.


It all sounds simple but actually achieving that


harmonious situation is very difficult in practice.


If your peer firms have better CPD, Project and


Programme Capabilities, IT and support services


don’t be surprised if your FCA Supervision Team


finds your systems and controls less than




There are also mindsets and cultural dispositions


that need to change too. Under FSA it would have


been common to position a firm’s regulatory efforts


to make an overall demonstration that there were


reasonable systems and controls in place. If you


like, with the firm and its Compliance team taking a


“tactical” approach to regulation investing in


“mitigation”, knowing that somewhere the firm would


fail. That looks like old fashioned thinking now as


FCA has made it very clear that generally “decent”


systems and controls are something of a “given”.


Post April 2013, there is an expectation that firms


will be able to show that the customer’s interest is at


the heart of the firm’s business model. Not easy.

Business Leaders need to really


know the Regulatory Landscape

With the establishment of a Three Lines of Defence


controls models now commonplace in firms, senior


management will be keenly aware of their


responsibilities and potential personal liabilities.


We would argue that management’s regular


business strategy meetings must-more than ever-be


supported by up-to-date and well informed


regulatory and risk thinking and awareness.


Especially in the retail sector with forthcoming


change s on platform payments, Solvency


changes, adviser charging still work-in-progress, the


mortgage market review and consumer credit


regulation to transfer to the FCA, there are multiple


and major challenges ahead.


Chief Risk Officers and Heads of Compliance have


challenging years ahead keeping their firms up-todate


and that ignores the ongoing attention required


by Governance and anti financial crime systems


and controls (including cyber security).


If you are to keep up with the regulatory and risk


Jones’s, the budget for risk and regulatory


resources must genuinely match the challenges



Contact/Action to discuss this article or any


other FCA related matters confidentially please




07794 612 430