Category Archives: Articles

Qualitative information and data-driven regulation

Both the Prudential Regulation Authority (the PRA) and the Financial Conduct Authority (the FCA) rely on data for supervisory purposes and Nikhil Rathi, Chief Executive of the FCA, has said that “Data is the lifeblood of a modern regulator and in the next five years, we expect to become as much a regulator of data […]

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Two suggestions for tackling micro-exclusions (with thanks to Adam Grant)

Diversity and inclusion remain high on the regulators’ agenda but their proposals are unlikely to address a trail of demoralising situations I’ve seen in practice. I call these micro-exclusions, the small and subtle actions that result in some being favoured over others, certain voices not being heard and those who don’t ‘get on board’ being […]

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The critical importance of fairy dust

Fairy dust – the sparkle that makes a presentation shine; the final adjustments that make the message compelling. It’s a dainty expression for a hard-working ingredient in submissions and presentations to regulators. Forget spin; this is about substance and structure. It might involve: Having a crystal-clear and confident narrative that carries the regulator through the […]

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What makes an outstanding board?

This started as an article about what makes a board of directors ‘effective’ but I decided that was aiming too low. Why shouldn’t a board be outstanding? Let’s begin though with board effectiveness. 1 Board effectiveness What made the board of a bank or other financial institution ‘effective’ a few years ago won’t hit the […]

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PREPARING FOR A VISIT BY THE FCA

Visits by the Financial Conduct Authority (the FCA) aren’t as common as they were pre-Covid but they still take place, usually as part of a thematic or sector review. They can be in-person (at a firm’s offices) or take place remotely. They might involve interviews of senior staff (not necessarily SMR senior managers) but there’s […]

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THE CONSUMER DUTY ANNUAL REPORT: POINTS FOR BOARDS TO CONSIDER

For firms subject to the Consumer Duty, the first annual report is on the horizon and a firm’s board of directors will need to review and approve the report, provide confirmations, carry out assessments and agree actions. The process involves more than simply reviewing and approving a document. The Financial Conduct Authority (the FCA) will […]

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PREPARING FOR SMF INTERVIEWS

I help a lot of applicants prepare for interview by the Prudential Regulation Authority (the PRA) and the Financial Conduct Authority (the FCA) as part of the senior management function approval process. Here are some points that might be helpful if you’re called for interview. 1           Check the application documents at least ten days before […]

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FCA STRATEGY FOR CONSUMER LENDING – DEAR CEO LETTER OF 20 MARCH 2024

In a Dear CEO letter issued on 20 March 2024[1], the Financial Conduct Authority set out its agenda for the next two years for three portfolios in the consumer lending market: high-cost lending; mainstream consumer lending; and credit unions. The FCA says that A significant part of our supervisory activity over the next two years […]

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