The FCA’s Mission and Business Plan published on 18th April leans towards promoting a level of transparency. The financial watchdog wants to be translucent in its decision-making, the work it does, the outcomes it expects, and how performance will be measured and it is welcome that Andrew Bailey seems resilient enough to set these expectations on the FCA as well as on firms.
The risk outlook section makes grim reading in general. But it is tinged with silver, particularly for those embracing technology. Based on our Wealth Survey results, we expect technology and IT system development to drive change to market structures and business models, and this view is supported by the FCA’s specific focus on the automated advice sector and non-advised drawdown sales.
Sector specific structural changes driven by legislation such as MiFID II and the widening impact of non-financial players in the market mean incumbent businesses may need to be prepared to direct significant levels of infrastructure investment to understand the interface of new tech and existing operational models to capitalise on cost savings from tech.
It is good news that the FCA will continue to create a permissive regulatory environment for innovation bringing consumer benefit. But its Business Plan is not all about tech. As important is that it reiterates, despite the continued unsettled situation following UK’s EU referendum [Brexit vote], that the FCA has not lost sight of its traditional, consumer protection agenda. It continues to stress the important link between culture, conduct and consumer protection concerns; risks from consumer vulnerability (from age, technological exclusion, or debt, for example) is a core theme; and the old chestnut of financial crime (whether money laundering or cyber-attacks) is still on the priority list.
In summary, a Business Plan for traditionalists and modernists alike, perhaps?