FSA has published its final report on its COBS post-implementation review. It looked not only at how firms had coped with COBS when it was introduced in late 2007 but also at some specific issues for the retail market:
- financial promotions and other communications;
- suitability and appropriateness; and
- disclosure and provision of product information.
Generally firms have not had trouble implementing COBS and have reviewed their procedures since implementation. If anything, firms found COBS easier to understand and comply with than its predecessor, COB. FSA found some smaller firms had not taken as much advantage as they might of the flexibility COBS offered and in fact asked for more prescription. FSA identified some areas where it has concerns on levels of compliance or interpretation of its rules, and will address these either by proposing rule clarifications or by providing help on its website. In other areas, it will await any EU action before planning changes to its rules.