Those of you trawling through Waterstones best sellers and bargain books (other book shops are available) may not have stumbled on the FCA Business Plan 2018-19.
You may be under the impression that after the excitement of MiFID II and GDPR, there is a lull. Indeed, there appears to be a period of grace but this, unfortunately, is a false dawn. The business plan outlines some 12 reviews, 8 publications and numerous other activities across all financial services.
Some of the “highlights” include the proposed Suitability Review 2019. A follow-up version of the highly successful 2017 review. (Is it me or do we seem to be following the same naming convention as the FIFA video game?)
The thematic priorities, which will have diverse methods of addressing and review, are:
- Culture and governance
- Financial crime and AML
- Data security, resilience and outsourcing
- Big data and fintech
- Treatment of existing customers
- High cost credit
Key priorities within these themes are finalising the rules of the Senior Managers and Certification Regime and monitoring the roll out of technology and resilience as part of the Open Banking and the second Payment Services Directive (PSD2) (with the ability for third party providers to access a client’s data and make payments, this will be an important test of the security of this directive).
Introspectively, the FCA are also testing and applying RegTech and advanced analytics to the approach to regulation which may open the door for firms to move to similar schemes. Also, the FCA will be creating a Memorandum of Understanding with the Information Commissioner’s Office. This may lead to a focus in certain reviews and questionnaires on data security.
We have not heard the last of MiFID II either and, although to date, a collaborative approach has been taken, we may see considerable more depth to the monitoring, particularly transaction reporting and the inconsistent approach to research costs.
So, enjoy the summer’s fine weather, holidays and sport and look forward to the next year or two’s regulation with a spring in your step and a passport in your hand (Brexit allowing of course).
As more details become available on each of the areas, we will publish a short pragmatic guide on what they mean and what you will actually need to do.