“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”