Nov 17 – The Compensation Contract
It is not often that I am heard to commit a “well done” to the FCA. However now is such a time based on their decision to re-consult on a new approach to funding the Financial Services Compensation Scheme. Rather than taking the soft option of picking one of the sub-optimal alternatives they had originally […]
Nov 17 – Data
With the deadline for the General Data Protection Regulation now just six months away, we still have the ICO finalising guidance whilst the Data Protection Bill is still making its way through Parliament. Not to mention the new Privacy Regulation which is supposed to be implemented at the same time, yet it’s still being agreed […]
Oct 17 – Later Life – in need of a chat
As the population benefits from living longer, the financial services sector needs to think about how it will adapt to meet their needs. As a population group that is going to need help and advice this should be the natural domain of the intermediary. Whilst we have seen some firms and brokers specialise in the Equity […]
Oct 17 – Planning ahead
As we move to the point in the year where business written has more impact on the numbers for 2018, firms and brokers should be beginning their planning for a changing world. The government commitment to Brexit at any price, even a no deal exit, is now beginning to weigh down on consumer and business confidence. […]
Oct 17 – A proper consultation process
We’re currently going through yet another period of regulatory and legislative changes – the extension of the Senior Managers and Certification Regime (SM&CR), General Data Protection Regulation (GDPR) and the Insurance Distribution Directive (IDD) to name but a few. Notwithstanding firms actually implementing the new requirements, a good process to engage with industry, fully consulting […]
Sept 17 – General Data Protection Regulation
In May we issued a newsflash on the General Data Protection Regulation which comes into effect on 25 May 2018. Firms should be starting to prepare for the changes now.
Sept 17 – Challenging Times
In this first AMI Mortgage Strategy column, I want to look at the key issues facing the modern broker in the post financial crisis but pre-Brexit world. Our market still faces huge uncertainty given the prolonged period of low interest rates which means that almost half of mortgage borrowers have never encountered a rate increase. […]
Sept 17 – Half the answers
Parliament amended FSMA in May 2016 to extend the Senior Managers and Certification Regime to all authorised firms. This emanated from the work previously done by the Parliamentary Commission on Banking Standards, which reported in June 2013, leading to a series of consultations by the PRA and FCA in 2014 and 2015 to capture banks […]
Sept 17 – 50 years without a better robot
Much is being made of the march of technology predicted to make redundant the traditional mortgage broker. Apparently we are soon to see the application of Artificial Intelligence, robo-advice models, enhanced sourcing, propensity modelling and direct to lender application and approval processes which spells the end for traditional approaches. As a child of the 1960s […]
Sept 17 – Ageing population
With the FCA’s report on their ageing population work due this autumn and the ongoing collaboration across the industry on later life lending, it is clear that education and communication is key. Older consumers are seldom aware of their options outside of pensions and residential mortgages. This is not helped by the lack of guidance […]
August 17 – Senior Managers & Certification Regime
The FCA has issued its first consultation on how the Senior Managers Regime, Certification Regime and Conduct Rules will apply to the remaining regulated firms. A second consultation on the technical aspects will be issued later this year.
August 17 – Nailed down
After great deliberation, the FCA is now consulting on “Individual Accountability: Extending the Senior Managers and Certification Regime to all firms”. This new regime will replace the existing Approved Persons regime and moves us from the reality of consumer detriment to the concept of “consumer harm”. It sets out a core regime with a standard […]