“regulation today, regulation tomorrow…” chris cummings director ami

“Regulation today, regulation tomorrow…”

Chris Cummings

Director AMI

AgendaAgenda

Regulation, regulation, regulation Don’t panic Do do… Last minute checklist Over the next wave…

Regulation, regulation, regulationRegulation, regulation, regulation

Europe HMT DTI OFT HM C&E

““It is a truth, universally acknowledged, It is a truth, universally acknowledged, that a market going through regulation that a market going through regulation

must be in need of more…”must be in need of more…”

FSA FOS FSCS The Courts

Do do…Do do…FSA’s objectives:

• To maintain market confidence in the financial system

• To promote public awareness of the financial system

• To provide consumer protection

• To reduce the opportunities for financial crime

FSA’s approach:

• Risk based approach

• Emphasis on systems & controls

• Formal control structure in all areas

Last Minute ChecklistLast Minute ChecklistInternal controls: PII levels

mortgage and protection levels Capital adequacy Regulated business plan SYSC requirements Inducements systems Senior management team Staff training on regulation

NILGI

Last Minute ChecklistLast Minute ChecklistCustomer facing: New business process reviewed

“independent” - fee option whole of market?

Introducer procedures Existing customers contacted ToB letters reviewed:

on-going contact customer opt-in data protection

IDD KFI provider confirmed Suitability letters

Last Minute ChecklistLast Minute ChecklistCustomer facing: Financial Promotions reviewed

transitional arrangements Record keeping requirements Systems to manage non-regulated business Scripted Q&A

Complaints procedure: Complaints procedure reviewed Training and competence: Focus on on-going competence requirements

What we expectWhat we expect

Willingness to listen to industry initiatives:– PII– Qualifications

Easy to do business with

A working relationship between industry and regulator: a social contract?

AMI expects: Catch our breath Room to breathe Co-ordination “Getting the bad guys” “Hidden agenda” No retrospection Costs of regulatory

bureaucracy

Over the HorizonOver the Horizon

FSA

• M&GI bedding in• FSA themes:

• Financial Promotions• Taking an interest• KFIs• Responsible lending• Policing the perimeter• Treating Customers

Fairly• Regulatory Reporting

Issues• Ombudsman• Home Reversions• Exam review• Europe:

• ISD; DMD etc• 30 CPs in 2004 • 80 CPs in 2005

• PI – capacity and cost• Buy to let• Events, dear boy, events…

Stand UpStand Up

AMI:– Insight– Information– Analysis– Industry Voice– Honest Broker– Helpdesk– Information rich website– Regional meetings

“Your voice in a hostile world”