Category Archives: Ruth’s Blog

Data Ownership: Mine or Yours?

The idea for this post comes from a book I’ve read recently – The Digital Ape by Nigel Shadbolt and Roger Hampson.  It’s a thought-provoking analysis of our interaction and relationships with digital devices, how artificial intelligence is already in our lives and ethical questions we’ll need to consider.  And it also considers the vast […]

Also posted in Ruth's Blog | Comments closed


I’ve helped prepare a lot of people for interviews – regulatory interviews where the individual is up for approval by the PRA or the FCA and interviews as part of regulatory visits, as well as interviews that have nothing to do with financial services.  I’m often asked for tips and here are a few; it […]

Also posted in Ruth's Blog | Comments closed

Spotlight on Non-executive Directors

The senior managers’ regime has upped the stakes for some non-executive directors (chairs of audit, risk, remuneration and nomination committees; the senior independent director; the board Chair) and there’s a danger of other NEDs falling by the wayside.  Here are some thoughts that might adjust that balance, looking through a regulatory lens.  General corporate governance […]

Also posted in Ruth's Blog | Comments closed


The FCA and the PRA have identified governance as a priority item to consider when authorising and supervising firms but what does this mean in practice? 1          Governance used to be synonymous with corporate governance – board composition, terms of reference, board committees and so forth.  Those days have gone.  There’s now project governance, product […]

Also posted in Ruth's Blog | Comments closed


Consider this scenario:  a senior manager at a bank meets the FCA on one of the regular Supervision visits and is asked about sale of a new product as the FCA has been receiving complaints about the product and the sales process.  The senior manager has overall responsibility across a number of areas of the […]

Also posted in Ruth's Blog | Comments closed


The beginning of September is a time to take stock after the summer, assess where we are and what’s ahead.  Here’s my assessment of the regulatory landscape. 1          There are specific topics on the radar – I’d put AML on the list (although it’s never really been off the list) and whistleblowing features strongly.  Expect […]

Also posted in Ruth's Blog | Comments closed


What has the Deepwater Horizon oil spill to do with banks’ capital charges and bank culture?  Perhaps more than might appear at first sight. The connection is a social licence to operate, where an organisation, a project or proposal or a sector of the market has broad social acceptance within the relevant community and amongst […]

Also posted in Ruth's Blog | Tagged , , , , , , | Comments closed


The FCA’s recent paper on culture (DP 18/2; Transforming culture in financial services – March 2018) has put the spotlight on embedding the culture of an organisation at all levels, which begs the question of how to achieve that.  I’ve found that narratives can help to do this. It’s a bit like using examples.  When […]

Also posted in Ruth's Blog | Comments closed

The FCA and the Culture Thing

The Financial Conduct Authority (FCA) has been concerned about the culture of financial institutions for some time and ‘culture’ has been a topic on the agenda at visits and review meetings.  Working out quite what the FCA means by ‘culture’ – and what it expected – has been a little harder to discern, but a […]

Also posted in Ruth's Blog | Tagged , , | Comments closed

Risk: Back to basics

Over the last few months, cyber-security risk has become the topic du jour for regulators and firms.  This should certainly be on the agenda, but it’s not the only risk topic.  Here are some more work-a-day issues that I’m seeing and hearing about. 1           Board risks vs Risk function risks – it’s remarkably rare to find […]

Also posted in Ruth's Blog | Comments closed