Dec 19 – Cultural Awareness

As a responsible trade body, AMI has always wanted an effective and efficient regulator.  In the FCA we have in the past enjoyed an open and participative approach built on mutual trust.  The MMR and FSCS funding consultation being two shining examples.

In support of FCA we have always had outstanding access and very open discussions.  Accordingly, it was no accident when in a meeting between senior AMI and FCA executives in mid-September we raised whether the culture at the regulator was effective or perhaps in need of attention.  The feeling we took away was that our concerns were not recognised.  Perhaps an organisation where the leadership sees the need to simultaneously change both its internal culture and the industries at any price.

Not surprising to us then for November to bring an internal FCA memo citing unsatisfactory staff drinking, theft, bullying and defecation.  For an organisation to need to issue this to 4000 staff speaks volumes.  Clearly so widespread it needed general circulation with tacit acceptance that if the story got out it was an acceptable risk.  The opposite would infer that management had lost all judgement and control.

Jeff Prestridge’s article in the Mail on Sunday on 17 November based around this set out the case and pertinent arguments with clarity.  It included quotes from the recruitment site Glassdoor “So much posturing, positioning, jockeying for favour, building fiefdoms.” and “ineffective at regulating markets.”

There are many people who are long standing excellent regulators and supervisors at the FCA.  Some I know well have felt impelled to walk away from projects in frustration at the agenda being pursued, whilst senior people appear to ignore the risks elsewhere in the landscape.  Possibly because not in their “line”.

This is just not good enough.  The industry pays for this regulator and it is failing good firms by addressing issues in the wrong way and ignoring poor industry behaviour by focusing on innovation and re-engineering markets at the expense of applying proper control.  Resource allocation and prioritisation is a genuine executive skill.

There have just been three new Board appointments and they really have to get under the bonnet of the organisation and find out what is really going on.  It is not enough to sit in meetings and be presented to through the filters of “PowerPoint” and management controls.  This is a job where walking the floor and really listening to the staff on the ground is the only answer.

With these obvious signs of organisational distress, one wonders what has been happening within the internal Whistleblowing process and the investigations which should have resulted.  AMI raised these issues out of genuine concern for a well-focussed regulator that gets to the heart of issues quickly.  We remain concerned about prioritisation of change agendas ahead of applying proper controls over their rules and ensuring integrity through sound “on the ground” market intelligence and hard supervision.  The firms who pay and the consumers they protect expect standards of the utmost integrity.

The Complaints Commissioner has been finding against this regime too often recently, with limited acceptance of those findings.  Some humility and less hubris might be order of the day.

Robert Sinclair, AMI
November 2019