May Regulation Update
By Kyte Ekstrom | Brexit, Compliance, Consumer Credit, Credit Brokers, Crypto-Assests, E Money, ESG, FCA Inovation Hub, FCA Regulation, Financial Promotions, FinTech, Insurance, Insurance Broker, payments | 0 Comments
GENERAL
FCA Publishes Speech – Regulating Finance for the Whole of the UK
The speech given by Charles Randell, FCA and Payment Systems Regulator (PSR) Chair, was delivered at the Centre for Commercial Law Studies, Queen Mary University of London.
Mr Randell focused on a number of points relating to the theme of ‘levelling up finance for the whole UK, and delivering better outcomes for people. Highlights from the speech include:
- the FCA needs to partner with a range of actors to develop partnerships to promote understanding of financial decisions from school age to the point of sale; address digital exclusion; and fight financial crime more effectively.
- with hindsight, more could have been done to protect people from the risks introduced by the pension freedoms policy, particularly if there had been more preparation time. The policy itself and the broader system to implement it were inadequate.
- the FCA has accepted, and is implementing in full, the recommendations of an independent review into the case of London Capital & Finance. Mr Randell states that combatting the large number of unsuitable and sometimes fraudulent investments in the market, and particularly those available online, is something the FCA cannot do alone.
- the project to bring speculative cryptoassets within the regulatory perimeter needs a workable operational plan which the FCA, and other regulators where appropriate, are committed to delivering. Mr Randell notes that regulating cryptoassets also means deciding how the FCA will meet the significant costs of that regulation. He comments that the financial services industry as a whole should not be exposed to the costs of failing cryptoassets firms through the Financial Services Compensation Scheme (FSCS) and that consumers need to be aware of that before investing in cryptoassets.
Mr Randell also discusses the Financial Services and Markets Bill, which Parliament will be debating in the coming months. He went on to share his thoughts on how to make sure the Bill achieve its aim, as set out in the Queen’s speech, to ensure that the financial services industry continues to act in the interests of all UK people and communities. Mr Randell also expressed concerns over the government’s proposed powers to intervene in the FCA’s processes, and highlighted the increased risk of lobbying and frequent interference.
Speech by Charles Randell: Listening up to level up – regulating finance for the whole of the UK
FCA publishes Market Watch No. 69 – Market Abuse Surveillance
Issue 69 of Market Watch, the FCA’s newsletter on market conduct and transaction reporting issues discusses firms’ arrangements for market abuse surveillance.
Market Watch No. 69 – covers matters including:
- market abuse risk assessments: Where firms do not consider different types of market abuse, the different areas of business in which they operate, how that business is undertaken, and the different asset classes and instruments traded, they may not be able to adequately identify market abuse risks and align their monitoring programme to them to ensure effective surveillance. This may also be the case where firms do not review and update their systems as necessary to ensure they remain effective in the context of risks arising from changes in their business.
- order and trade surveillance: The FCA’s interactions with firms indicate that surveillance arrangements are improving across industry, however, there continues to be variance. While the FCA have seen examples of comprehensive, tailored systems, accurately aligned to risk assessments, they also saw instances of little or no monitoring taking place.
- policies and procedures The FCA noted that where firms have created policies and procedures in relation to monitoring for market abuse, that they have seen a variety of approaches. Some have clear, detailed and up-to-date policies and procedures and it appears these may provide a helpful reference point for staff and assist with work in areas such as alert review and escalation. The FCA also observed instances where policies and procedures are vague or have limited detail, such as directing analysts reviewing surveillance alerts to look for signs of market abuse.
- outsourcing The FCA found that, in some cases, there is a limited understanding and/or oversight of the surveillance taking place. The FCA reminds firms that responsibility for identifying and reporting potential instances of market abuse rests with the UK entity subject to the obligations under the retained UK law version of the Market Abuse Regulation (596/2014/EU) (UK MAR) obligations.
- front office To ensure staff act appropriately, the FCA encourages firms to consider whether their market abuse training is effective and tailored to the risks associated with the desk, asset classes traded, client types and other relevant factors.
- Countering the risk of market abuse-related Financial Crime
To comply with their obligations, the FCA state that firms would benefit from ensuring they have a good understanding of the risks that are relevant to their business, as well as robust controls to mitigate those risks.
The newsletter concludes with, Investigations into potential market abuse by firms’ employees. The FCA remind firms subject to Article 16 of UK MAR that they should also consider the requirement to submit a STOR without delay, once they have a reasonable suspicion that an employee’s conduct could constitute as market abuse. This may be before the full internal investigation is concluded.
FSCS Publishes Update – Annual Levy 2022/23
The annual levy for 2022/23, as announced by the Financial Services Compensation Scheme (FSCS) is now £635 million. This represents a decrease of £265 million on the figure forecast in November 2021 and a £92 million decrease on the final 2021/22 levy. In the update the FSCS explain that the updated levy is driven by a £128 million decrease against compensation paid to customers in 2021/22, which resulted in surpluses being carried forward into 2022/23 and a decrease of £162 million in compensation forecasted for 2022/23.
Although the levy forecast has decreased, the FSCS notes that they still expects compensation costs in 2022/23 to be higher than for 2021/22.
Operational Resilience – PRA Publishes Speech
The PRA has published a speech delivered by Duncan Mackinnon, PRA Executive Director for Supervisory Risk Specialists, at the City & Financial 9th Annual Operational Resilience for Financial Institutions Summit. In the speech, Mr Mackinnon sets out where the PRA expects firms to focus as they work towards building operational resilience by March 2025. The Bank’s, the PRA’s and the FCA’s operational resilience policies came into effect on 31 March 2022.
Key points from Mr Mackinnon’s speech include:
- Scenario testing: Mr Mackinnon notes that the scenarios a firm uses should assume disruption has occurred. They should include data integrity scenarios and incorporate third party disruption, consider factors beyond the firm’s control and include cases where multiple parts of the organisation are disrupted simultaneously. The form of testing a firm uses must be robust and appropriately in line with its potential to affect its own important business services and the wider system. For high impact important business services within systemic firms, Mr Mackinnon cautions that desktop testing is unlikely to be sufficient.
- Building resilience: the PRA’s focus is on whether firms can achieve the operational resilience policy’s ultimate outcome and remain within impact tolerances, not on how firms go about building this resilience. The PRA cautions that the longer firms take to map to the required level of sophistication and to run robust scenario tests, the shorter the period they will have to address their vulnerabilities and build resilience.
- International: the PRA will continue to work with EU partners through the European Systemic Cyber Group, which has recently issued a recommendation to establish a pan-European systemic cyber incident coordination framework. In its work the with the G7 Cyber Expert Group, the PRA is prioritising the need to address the increasing threat of ransomware.
- Embedding operational resilience: the PRA expects operational resilience to become a major consideration in firms’ investment programmes. Mr Mackinnon notes that firms can leverage other frameworks to address operational resilience requirements. For example, he points out that the scenarios a firm uses for the operational risk element of their Internal Capital Adequacy Assessment Process might be used as part of the implementation of its operational resilience policy, and comments that the PRA’s March 2022 outsourcing and third party risk management policy is also relevant to firms’ resilience. However, Mr Mackinnon stresses that, where other frameworks are leveraged, the expectations in each policy must still be met in full.
Mr Mackinnon also sets out a number of future PRA initiatives which are aimed at enhancing the resilience of the financial sector. The 2022 exploratory cyber stress test will look at firms’ capabilities and the potential financial stability impact of a hypothetical scenario. The Bank, the PRA, the FCA and HM Treasury are also working to develop measures to manage the risks to UK financial institutions posed by critical third parties and will publish a joint discussion paper later in 2022 to inform future regulatory proposals. The PRA also highlights its recent Policy Statement (PS2/22) on operational resilience and operational continuity in resolution. Mr Mackinnon notes that firms and holding companies should be taking a group level view of operational resilience, ensuring that risks arising in parts of the group that are not subject to the individual requirements are considered.
FCA Publishes New Webpage – Reporting Evasion of Sanctions
The new webpage provides information for firms on ways to report evasion of sanctions or weaknesses in sanction controls. The FCA want to hear about sanctions evasion issues where they relate to firms on The Financial Services Register or the FCA’s other registers, or companies with UK listed securities. The webpage also provides information on what can be reported to the FCA and how to report a firm or an individual.
Webpage: Reporting sanctions evasions
FCA Publishes Policy Statement (PS22/5) – New Cancellation and Variation Power in FS Act 2021
Policy Statement (PS22/5) covers changes to the FCA’s Handbook and Enforcement Guide to reflect the new cancellation and variation power granted under the Financial Services Act 2021. The power (set out in Schedule 6A to FSMA 2000), allows the FCA to vary or cancel firms’ permissions more quickly and efficiently if they are no longer using them.
The FCA is proceeding with the proposed changes, as previously consulted in CP21/16, with one minor change which is designed to make it clearer that the FCA will consider all relevant facts and circumstances when deciding whether to use the new power.
In the accompanying press release, the FCA draws attention to their ‘use it or lose it’ exercise. Since May 2021 the FCA has conducted over 1,000 assessments to see whether firms are undertaking the financial activity for which they have permission. So far, this has resulted in 264 firms applying to voluntarily cancel, and 47 to modify, their permission to carry out regulated activities.
The FCA’s final amendments to the Handbook and Enforcement Guide are set out in appendix 1 to the Policy Statement. The changes apply only to firms that are authorised, or deemed to be authorised under the temporary permissions or supervised run-off regimes, by the FCA under Part 4A of FSMA 2000. The changes will not apply to firms authorised by the PRA, nor to firms authorised by the FCA other than under Part 4A, for example payment service providers.
FCA Publishes Speech – Learning from Innovation
The speech delivered by Nikhil Rathi, CEO of the FCA, provides the FCA’s perspective on what can be learned from the last 30 years; with a particular focus on innovation. Mr Rathi highlighted, among other things, that:
- digital skills will be integrated in all future financial services education, including at the FCA, as the boundaries become blurred between tech and the industry.
- the Digital Regulation Cooperation Forum (DRCF), of which the FCA is a member, is focusing on protecting children online, which is relevant for the FCA as it is seeing ever younger participants (including children) in new financial products like cryptoassets.
- in one year, the FCA has seen over 2,000 cases of screen sharing scams where victims have lost £25 million. The ‘ScamSmart’ campaign, launched on 5 May 2022, aims to tackle this.
Financial Services and Markets Act Bill – Queen’s Speech
The Queen’s Speech, delivered by Prince Charles at the Opening of Parliament, sets out the government’s legislative agenda for the next parliamentary session.
The speech touched on three bills that will be of interest to financial market participants:
- the Retained EU Law Bill, also known as the Brexit Freedoms Bill.
- the Financial Services and Markets Bill.
- The Economic Crime and Corporate Transparency Bill.
The Financial Services and Markets Bill builds on the Financial Services Act 2021 and will ‘strengthen the UK’s financial services industry, ensuring that it continues to act in the interest of all people and communities.’
The main elements of the Financial Services and Markets Bill are:
- revoking retained EU law on financial services (including Solvency II) and replacing it with an approach to regulation that is designed for the UK.
- updating the objectives of the financial services regulators to ensure a greater focus on growth and international competitiveness.
- reforming the rules that regulate the UK’s capital markets to promote investment.
- ensuring that people across the UK continue to be able to access their own cash with ease.
- introducing additional protections for those investing or using financial products, to make it safer and support the victims of scams.
In an associated press release, HM Treasury notes that the Financial Services and Markets Bill will also enable the Payment Systems Regulator (PSR) to require banks to reimburse authorised push payment (APP) scam losses, totalling hundreds of millions of pounds each year. This statement coincides with the publication of a policy paper in which the government sets out their approach to APP scam reimbursements.
HM Treasury press release: New law to protect access to cash announced in Queen’s speech
Policy Paper: Government approach to authorised push payment scam reimbursement
DCMS and BEIS Publish Government Response to Consultation – Pro-competition Regime for Digital Markets
The Department for Digital, Culture, Media & Sport (DCMS) and the Department for Business, Energy & Industrial Strategy (BEIS) have published the government response to the July 2021 consultation on the proposed new pro-competition regime for digital markets, and the establishment of the Digital Markets Unit (DMU).
The vast majority of respondents to the consultation supported the government’s proposals for the regime. Many provided evidence of the need for urgent action to ensure the government has the regulatory tools needed to address the challenges arising from weak competition in digital markets. Respondents also emphasised the need to equip the Digital Markets Unit (DMU) with the ability to respond rapidly and with flexibly on fast moving issues in digital markets.
The government has outlined the core tenets of their new regime, these include:
- a DMU with the core objective to promote competition in the digital markets for the benefit of consumers, with a duty to consult with other regulators where proportionate and relevant.
- a targeted focus on a small number of firms with substantial and entrenched market power, which gives them a strategic position (‘Strategic Market Status’) in one or more activities, determined by a minimum revenue threshold.
- a DMU which is empowered to make pro-competitive interventions, such as those made to support interoperability.
- a DMU with the power to impose financial penalties of up to 10% of a firm’s global turnover for regulatory breaches, and to apply to the court to disqualify individuals from holding directorship roles in the UK.
The government also intends to introduce new requirements for firms with Strategic Market Status to report merger transactions to the Competition and Markets Authority (CMA) prior to their completion.
The government intends to legislate to implement these reforms when parliamentary time allows.
Government response to the consultation on a new pro-competition regime for digital markets
FCA Publishes Speech – Critical Issues in Financial Regulation
The speech delivered at City Week 2022 by Nikhil Rathi, CEO of the FCA, provides the FCA’s perspective on critical issues in financial regulation.
Highlights of the speech include:
- Cost of living crisis means consumers are more exposed to risk and more reliant on financial services.
- New consumer duty will ensure firms take into account ‘good outcomes’ for consumers and clear rules will in future cut costs for firms.
- Supporting innovation to encourage long-term economic growth and international competitiveness:
- Extending an early oversight scheme to give 300 newly authorised firms guidance on regulatory issues as they grow
- Over 500 applications to attend our first ever CryptoSprint event in May
- Post-Brexit, if you are a predominantly UK business, your regulated entity should be here to protect investors and the integrity of the markets.
Expanding the highlights, below are collated relevant key points from the speech.
Cost of Living Crisis
With inflation set to reach an all time high, the cost of living crisis means consumers are more exposed to risk and more reliant on financial services. The FCA’s focus is to ensure all regulated firms act in their customers’ interests. The FCA’s Three Year Strategy, published in April 2022, sets out market-wide outcomes which the FCA expect all firms to deliver.
New Consumer Duty
In December 2021 the FCA consulted on ‘A New consumer duty’. Final proposals can be expected to be published in July 2022. The ‘New Consumer Duty’, is designed to ensure firms take account of the actual impact of their services and product suitability on consumers.
Significant policy changes will include:
- action to tackle competitors who drive down standards
- giving firms greater certainty about how they should treat consumers and flexibility on how they deliver good outcomes
- supporting future innovation by being clear about the standards required, whatever the product
The FCA envisage fewer future rule changes as a result, which should lower costs to firms
Supporting Innovation
Extending an early oversight scheme to give 300 newly authorised firms guidance on regulatory issues as they grow.
The FCA’s CryptoSprint event being held on the 10th – 11th May 2022 has already received 500 applications wishing to attend. The event is intended to explore how the evolving world of cryptoassets could be regulated within the UK.
The FCA’s pioneering ‘sandbox’, a regulatory safe space to test innovative products, which has, so far, supported the growth and innovation of over 50 blockchain firms.
Environmental, Social and Governance (ESG) reforms: the FCA mandating climate related disclosures which were introduced in January 2022.
Diversity and Inclusion: the FCA recently confirmed positive diversity targets for listed companies, which firms must comply with or explain to their investors why they are not. These Diversity Inclusions include, that 40% of Board seats should be held by women and at least one position should be held by a minority ethnic director.
Post-Brexit
The FCA remains committed to a system that allows firms to provide cross-border financial services in a way that protects consumers and markets. As the Temporary Permissions Regime comes to an end, businesses focussed predominantly in the UK should set up an FCA authorised subsidiary in order to protect investors and the integrity of the markets.
Facing the Future
The FCA’s new strategy has an overarching focus on:
- reducing and preventing serious harm
- setting and testing higher standards
- promoting competition and positive changes
FCA Publishes New Webpage – Early and High Growth Oversight
The new webpage published by the FCA on ‘early and high growth oversight’ initiative, follows the success of the Initiative’s pilot scheme, which ran from October 2021 to March 2022 across 32 newly authorised firms.
The Initiative, designed to help firms meet their regulatory obligations in the first few years after authorisation, provides enhanced supervision and supports firms in understanding their obligations so they can meet FCA standards. The FCA explains that the Initiative will also assist in more quickly identifying and addressing harm which develops in newly authorised firms. The Initiative’s objectives are to:
- spot harm or misconduct.
- raise standards of newly authorised firms.
- promote competition.
- improve firm experiences.
The FCA sets out that, over 2022 to 2023, the Initiative will take in up to 300 newly authorised firms. No applications are necessary and the FCA will contact firms directly if they are included.
The webpage also sets out the findings of the Initiative’s pilot scheme, including those relating to financial promotions, regulatory submissions and permissions, financial projections and innovation.
The FCA has set out the following considerations for firms seeking authorisation:
- before and during the authorisation process, firms should ensure they read all the relevant information and guidance provided by the FCA. For example, portfolio letters or guidance relevant to their sector or business.
- firms should register for access to the FCA’s systems early on and should familiarise themselves with their reporting schedule once it is available.
- firms are reminded that, once they receive authorisation, they are subject to the FCA’s rules and principles. The FCA expects firms to engage openly and transparently and to notify them if it is likely that they won’t be able to fulfil their regulatory obligations.
HM Treasury Publishes Response to Consultation – Access to Cash
The response to HM Treasury’s July 2021 consultation on the government’s proposed policy approach to protect access to cash through legislation. The response sets out the findings from the consultation, as well as the government’s plans for legislating for the relevant measures in the upcoming Financial Services and Markets Bill.
In April the government announced intention for legislate in order to provide the Bank of England with the powers necessary to ensure the UK’s wholesale cash infrastructure – which includes the network of cash centres integral to the sorting, storing and distribution of notes and coin – remains effective, resilient, and sustainable, and continues to support access to cash across the UK. Taken together, these measures will ensure that the UK’s cash infrastructure is viable for the long term.
These powers will be legislated for in the upcoming Financial Services and Markets Bill, which will protect consumers and enhance the UK’s position as a global leader in financial services.
- Millions of people in communities across the UK will see their ability to access cash protected.
- For the first time, the UK’s largest banks and building societies will be subject to new Financial Conduct Authority powers to ensure the continued availability of withdrawal and deposit facilities in local communities across the UK.
- Measures will be legislated for in the upcoming Financial Services and Markets Bill which will protect consumers and enhance the UK’s position as a global leader in financial services
Under the new rules, the financial regulator – the Financial Conduct Authority (FCA) – will be granted new powers over the UK’s largest banks and building societies, to ensure that cash withdrawal and deposit facilities are available in communities across the country.
HM Treasury Consultation: Access to Cash: Summary of Responses
CONSUMER CREDIT
FCA Publishes Dear CEO Letter to Consumer Credit Firms – Financial Promotions
The Dear CEO letter, sent to approximately 28,000 credit brokers and firms providing high-cost lending products, set out the actions needed to ensure financial promotions are clear, fair and not misleading.
As a result of the cost of living crisis, the FCA expects to see greater demand for credit. This includes short-term credit, which will particularly impact consumers in vulnerable circumstances. The FCA will therefore be keeping the sector under close review to ensure that demand does not result in unsustainable and unaffordable lending.
The FCA identifies a number of practices that are of concern, these include:
- a number of financial promotions where firms include phrases such as ‘no credit check loans’, ‘loan guaranteed’, ‘pre-approved’ or ‘no credit checks’. The concern is that consumers could be led to believe that the lender will make no checks on credit status.
- promotions offering brokerage/direct lending services for high-cost short-term credit, which fail to specify the required risk warning in breach of CONC 3.4.1R.
- that some promotions fail to include the representative APR when required under CONC 3.5.7R and 3.5.8G.
- promotions by credit brokers, which fail to state that they are brokers and not lenders as required by CONC 3.7.7R.
In response to these concerns, the FCA outlines a number of actions for firms, including encouraging firms to review their processes, systems and controls for financial promotions to determine whether they are sufficiently robust.
The FCA intends to monitor the market proactively to assess compliance. Later in 2022, the FCA will confirm the final rules on the new ‘consumer duty’.
PAYMENT SERVICES, E-MONEY OPEN BANKING
PSR publishes Consultation Paper (CP22/2) – Confirmation of Payee
The Payment Systems Regulator (PSR) has published a Consultation Paper (CP22/2) on requirements for further participation in the Confirmation of Payee (CoP) service. The Consultation Paper follows the PSR’s August 2019 Specific Direction (SD10), issued to the six largest banking groups, requiring them to send and respond to CoP requests. The PSR published a Policy Statement (PS22/1) in February 2022 detailing the next steps for the wider implementation of CoP as set out in SD11.
The PSR is now proposing to give a new Specific Direction requiring approximately 400 PSPs to implement a system to offer the CoP service to their customers (both as payers and payees). The PSR explains that, because of the volume of PSPs involved, the proposed measures would split the requirements for PSPs to implement a system to provide CoP into two groups:
- group 1: This group will be prioritised based on the complexity and size of the institution or firm where the adoption of CoP could have the biggest impact in preventing authorised push payment (APP) fraud. Almost 50 PSPs will be required to have in place, and use, send and respond CoP capability from 30 June 2023. The PSR anticipates this would increase CoP coverage from 92% of transactions made via Faster Payments to 99%.
- group 2: Over 350 PSPs to have in place, and use, send and respond CoP capability from 30 June 2024. This group includes all other firms which use either unique sort codes or that are building societies using a Secondary Reference Data reference type.
The deadline for responses is 8 July 2022. The PSR will consider responses in deciding whether to proceed with the proposed Specific Direction. If so, this will be published between eight to 10 weeks after the deadline for responses.
PSR Panel Publishes Report – Digital Payments Initiative
The Payment Systems Regulator (PSR) Panel, provides independent advice and input to the PSR. The report published by the Panel on the PSR’s Digital Payments Initiative concluded that there are four high-level areas that need to be worked on to address the drivers of cash reliance and enable greater take-up of digital payments.
The four high-level areas are as follows:
- improving consumers’, small businesses’ and other small organisations’ awareness and understanding of, and trust in, digital payment options.
- tackling barriers to new digital payment services and service features, including enabling new functionalities and improving trust by addressing fraud risks.
- reducing digital exclusion.
- putting better data in place to monitor the transition to digital payments.
The report made 12 detailed recommendations across these four areas, and considered emerging developments across the payments sector. In particular, the Initiative identified that open banking could be key to developing digital payment services that better meet the needs of users, including those who currently prefer to use cash.
INSURANCE
FCA Publishes Speech – Insurance Brokers
The speech by Sheldon Mills, FCA Executive Director, Consumers and Competition was delivered at the British Insurance Brokers’ Association Conference on the 11th May 2022.
Mr Mills focuses on a number of points related to the theme of serving consumers and businesses in times of uncertainty and change.
Highlights of the speech include:
- the FCA’s commitment to supporting innovation, growth and competition in the sector.
- The rising cost of living forcing consumers into difficult decisions around what they spend their money on which may lead to consumers to opting out of certain types of insurance or reducing the level of cover for existing policies.
- A key area of the FCA’s strategy is to minimise risk and ensure that firms are resilient financially and operationally. FCA rules require that firms safeguard client money and maintain adequate wind-down plans to protect consumers from the risk of business failure.
- The FCA is determined to make their authorisation gateway stronger, and are working to bring down our timescales for considering applications.
- the FCA has noted the industry’s concern about the proportionality and cost of regulation and is reviewing their regulatory and redress framework to ensure that its scope and funding is appropriate and proportionate.
- Mr Mill talks briefly about diversity and inclusion, touching on statistics and studies of gender diversity and the positive impacts of a diverse workforce.
- The FCA’s ESG strategy has set out five themes that the FCA will work on: promoting transparency, building trust, utilising our full range of tools, supporting the UK’s transition to net zero, and building their team and capabilities.
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