Consumer Duty – an update

Key Consumer Duty developments and recent communications issued by both AMI and the FCA, with commentary on implications for mortgage intermediary firms…

AR regime – updated AMI Q&A and deadline reminder

Having heard back from the FCA, we have updated AMI’s Q&A documenton the AR regime. We also wanted to remind firms of the upcoming 30 November 2023 deadline…

FCA application window open for firms approving promotions for unauthorised persons

Firms that approve financial promotions for unauthorised persons have until 6th February 2024 to apply for approver permission from the FCA…

FSCS levy and compensation figures update

The FSCS has released an update on its levy and compensation figures for 2023/24, as well as anticipated levy figures for 2024/25…

AMI unveils The Perception Gap, the fourth annual Protection Viewpoint

This Viewpoint features hot topics facing the industry, including value of advice, building trust, consumer buying habits and generational views & attitudes…

Your October update from AMI Chief Executive Robert Sinclair

AMI Chief Executive Robert Sinclair gives his October update, focusing on AMI’s Protection Viewpoint, new build and Consumer Duty…

Edit Content

Log in here for full access to all our great content


Please log in below with your username (which is your email address), using all lower-case letters.


Forgotten your password?
No problem, simply tell us you have forgotten your password to receive instructions instantly via email.

Having problems logging in?
If you are a current member but are unable to login, please first make sure you are using all lower-case letters for your username/email address. If you still have difficulties, please contact us via email at so we can rectify your problem.

Not a member?
Learn more about the benefits of becoming a member or apply online and we will be in touch.

In the recent policy and supervisory work from both the PRA and the FCA much has been made of the culture within a firm.  There is a growing recognition that whilst a robust rulebook and well-established principles alongside the Senior Manager regime provides a framework, it is how a firm thinks and operates that needs closer focus and attention.

In order to help firms consider these issues more deeply the FCA has issued a discussion paper on transforming culture within financial services.  It comprises a collection of 28 essays from industry, academics, international regulators and change practitioners.  Interestingly whilst many banks were asked to contribute, insurers, fund managers and distribution were not.  However on 19 March 2018 the FCA held a full day workshop on culture, at which Andrew Bailey spoke and external presentations were given with active participation from the wider industry.

Responses to this paper are not invited but the FCA expects firms to consider the issues in the paper and to engage in the debate about what constitutes a healthy culture and how to promote it.  Financial services leaders and practitioners are expected to consider how they effect change in their organisations, by:

From the papers and discussions a number of key themes emerge that all firms including the mortgage sector need to consider as part of the way they do business and interact internally and externally.  What was not in any way questioned was that there still needs to be significant change to the culture within the vast majority of financial services firms.

At the workshop, consensus was that cultural leadership must start in the boardroom.  Firms need to consider how visible is their board, CEO and senior management team.  They must demonstrate and own the culture.  However whilst the tone of voice from leadership is key, top down implementation is not enough.  There needs to be transparency, commitment and buy-in from all levels. It has to be woven into the firm’s governance framework.  Many commentators see it as not about stopping bad things, but about promoting good things and excellence.

Perhaps it is better to see culture as clarity of purpose not just values; what do people actually think and do?  What is it that drives and motivates them?  There will not be one good culture, but various approaches, dependent on size, style, product, consumer type and values.  Good culture needs courageous leadership, direction, good decision making and authenticity.  No one has all the answers, but to succeed firms need to build new teams across traditional structures and ensure extensive participation and expansive communication.

Ownership of culture must run like blood through the organisation – bottom up and top down, with the right tone of voice and people will have to want to do it.  Transparency is thought by many to be all in culture – sunlight is the best disinfectant.  As a core component there is a fundamental need for diversity in all its facets to provide good challenge and to match the society we operate within.

As a part of the workshop discussions some considered that the plethora of rules, compliance approach to controls, and FCA approach to supervision and enforcement could be considered as part of the problem as people are focussed on fear of breaches not on excelling.  The regulator needs to help by holding up a mirror to help firms identify their issues – but in a supportive role not as a supervisory critic.

The FCA will continue to explore ways to improve culture in financial services by engaging with industry to gather practical examples of how the insights from this paper can be applied in practice.  Part of this will include looking at questions such as how to raise management of ‘culture’ as a leadership discipline to the level of rigour and importance as ‘strategic planning’ and ‘risk management’.  In any assessment there will be the firm’s brand values, its cultural values and its people’s personal values – good firms will bridge these and align to a common purpose.

Robert Sinclair
April 2018


Forgot Password?

Join Us