The Good King FCA last looked out
Like you, I get most of my Brexit updates from the @Coldwar_Steve twitter account. Based on this, Boris Johnson is currently panic buying Fray Bentos tins from a reconditioned ice cream van.
The UK’s exit from the EU will doubtless create challenges for Business owners, Client Relationship owners and Compliance Officers. They all need to understand any changes in order not to fall foul of the regulations after March 2019. The FCA have published two consultation papers, setting out its proposed approach on the UK’s exit from the EU in the event of a ‘hard’ Brexit.
Open-heart surgery is something one would want to avoid where our own health is concerned. Yet in businesses we seem to be witnessing such when it comes to established firms moving their businesses between technology providers.
The Insurance Distribution Directive (IDD)concerns the distribution of insurance-based investment products (IBIPs). It also covers firms that assist in the administration and performance of an insurance contract post-sale. It aims to create a level playing field for all those involved in the sale of insurance products.
With The FCA revisiting the implementation of MiFIDII and with the next Suitability review, and SM&CR also on their way, we are now seeing far more focus on disclosure, transparency, accountability and roles and responsibilities.
The term 'RegTech' was coined in 2015 by the Financial Conduct Authority, which described it as “a sub-set of FinTech that focuses on technologies that may facilitate the delivery of regulatory requirements more efficiently and effectively than existing capabilities".
What if the regulatory handbook was machine-readable and your firm could assess select rules, apply to the business’s data, tasks and actions and interpret this and report back to the regulator at a click of button?
The missing link between advice suitability and appropriateness of product in meeting client needs was delivered for retail investment advice firms with the introduction of Product Governance and distribution rules i.e. PROD 3.3 in particular.
One of the biggest risks we see Retail Intermediary Advisers (RIAs) make is confusing compliance and business risk. For example, recommending a product that is deemed suitable to meet current client needs doesn’t make it a good risk when viewed from a business legacy viewpoint i.e. client circumstances change, their perceptions change thus their trust and informed consent is at risk if they are not serviced correctly and thus lost trust and complaints become a business risk via fines and damaged reputation or worse.