Category Archives: Ruth’s Blog

Competition and the FCA

Competition seems to be the buzz word du jour.  The FCA has just issued its feedback statement on competition in the mortgage sector (FS 16/3) and the companion MMR responsible lending review (TR 16/4).  An interim report from the market study on investment and corporate banking was issued last month and the final report is […]

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REVERSING THE REVERSED BURDEN OF PROOF

So, the bête noir has been slain.  Those subject to the senior managers regime won’t have to prove they took the steps it was reasonable for someone in their position to take to prevent a regulatory breach occurring.  Instead, it will be for the relevant regulator to prove that a senior manager failed to prevent […]

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FOR THOSE NEW TO THE SENIOR MANAGERS REGIME AND THE CERTIFICATION REGIME

The whole of the financial services industry is about to face what banks, building societies, insurers and a few select others have been facing for a while now. The senior managers regime (SMR) and the certification regime (CR) are to be extended.  So, what do the regimes involve and what do they mean in practice?  […]

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THE NEW REGIMES FOR INDIVIDUALS – EXTENSION AND RETREAT

Now here’s a surprise (or not): changes are afoot in the regulatory regimes that apply to individuals.  A summary and a few thoughts on the key changes are set out below. 1          Extension of the regimes to all sectors of the financial services industry – it had to happen.  Continuing the approved persons regime alongside […]

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The certification regime: some practical points

The certification regime has tended to attract less attention than the senior managers regime. It might be because the potential sanctions under the certification regime don’t have the same headline-grabbing quality of the senior managers regime or because there’s a perception that there’s plenty of time to tackle the certification regime. Here are ten points […]

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Boards and the senior managers regime

I’m seeing a lot of attention being given to the senior managers regime and directors are getting to grips with what’s involved.  There are, though, some board-specific points that shouldn’t fall by the wayside.  Here’s a selection. 1          Not all directors are equal – it’s a further evolution of recent trends, but the senior managers […]

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FCA Business Plan 2015/16: a personal take

The FCA issued its 2015/16 business plan last week, packed with objectives and analysis.  Here’s a personal take on points that struck me, with an admittedly retail bias. 1          Culture – not surprisingly, culture features as a key topic.  It’s seen as a key driver behind the behaviour of those working in firms and the […]

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Culture centre-stage

I caught part of the interview with Antony Jenkins (CEO of Barclays) on BBC Radio 4’s Today programme this morning and something he said chimed with a few points I’ve come across recently.  When asked if he knows everything that’s currently happening within the bank (this being a particularly hot topic just at the moment), […]

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Blog 2.0

I’ve just been looking back at old blog entries after a long period without any posts.  I’d intended to delete all of the old entries and start afresh, assuming that they’d all be out of date. To an extent, they are and my assumption was correct, but what struck me is that topics I was […]

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Culture: headline and subtext

It’s one of those topics that won’t go away and it’s a topic that’s notoriously difficult to define, but culture is very much on the FCA’s agenda. As far as definitions go, it’s probably a combination of: What people do even when they think nobody’s looking; The mind-set of people within an organisation and how […]

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