The FCA Business Plan for 23/24 was published this month, setting out the regulator’s plans and areas of focus for the next year . I’ve picked out some of the areas I think are going to be most important to Financial Services firms and Banks over the next 12 months, and want to highlight how Kind Consultancy can assist your business with each one.
Buy Now Pay Later
Responding to a proposal from the Treasury, the FCA will set out over the next year how they will begin regulating previously-exempt Buy Now Pay Later (deferred payment credit) services. This will completely shake up the sector, as we’ve seen happen every time an unregulated product becomes regulated. At Kind Consultancy we have extensive experience of helping organisations prepare for authorisation, with specialist consultants available to shepherd your organisation through the business. We are a leading Compliance recruitment firm and are perfectly positioned to source and supply Compliance staff at all levels – including senior people who can design and build frameworks.
Vulnerable Customers
Consumer Duty is the biggest change currently taking place in the regulatory landscape and the FCA Business Plan reiterates they one of the key desired outcomes for the regulator is to make sure firms are supporting their customers who are facing difficulties, and providing those customers with the information they need to make good decisions. The Plan also acknowledges the ongoing rise in the cost of living, interest rates and inflation and how this is quickly pushing people into vulnerability. Kind can connect your firm to consultants with specialist knowledge in this area to review your processes and ensure any areas posing potential risk to vulnerable customers are recognised and resolved.
Financial Crime
Financial Crime is always important to the work of the FCA and is a prominent theme within the Plan. The FCA is looking to use technological solutions to identify more financial criminals before they can commit fraud, as well as raising standards for authorised firms to improve organisations’ ability to fight Financial Crime. Financial Crime recruitment has long been one of the central pillars of our work at Kind, and we have a substantial bench of experienced KYC and AML Analysts ready to deploy on contract projects – as well as a number of more senior contractors who have the knowledge needed to assess your organisation’s current AML systems and processes.
Redress Systems
The FCA is concerned that too many firms are failing to provide appropriate and efficient redress to customers when things go wrong. This year the regulator will consult on how they guide firms on redress exercises, review the rules on Ombudsman access for small and medium-sized firms and develop proposals to improve complaint reporting. Kind Consultancy can help your organisation stay ahead of this issue with expert consultants who are equipped to review your current redress processes and procedures and identify and drive any improvements needed.
Oversight of Appointed Representatives
Principal firms are responsible for ensuring that their Appointed Representatives are fully compliant with all FCA rules – but the regulator is concerned that many ARs are not being adequately overseen and that customers are at risk of being mis-led and mis-sold as a result. This year the FCA says they will “test” that firms are fulfilling their duties around their Appointed Representatives, and will engage with them more frequently. Kind Consultancy can provide regulatory compliance experts to train your Appointed Representatives and to conduct thorough compliance reviews on your ARs to ensure they’re ready for any FCA scrutiny.
Financial Promotions
Financial Promotions appear again and again throughout the Business Plan, clearly a major area of concern for the regulator at present. Plans for this year include bringing in Financial Promotions rules for previously unregulated sectors (ie. Cryptocurrency) and a commitment to intervening faster and with more serious penalties where a promotion is found to be non-compliant. Kind Consultancy works with a number of Compliance professionals with specific Promotions expertise, who can work with you to review your Promotions and ensure any potential issues are rectified.
Operational Resilience
Finally, Operational Resilience will be increasingly important this year, with the plan highlighting “minimising the impact of operational disruptions” as one of the areas the FCA wants to improve. The regulator is committed to “scaling up” their approach to handling firms who don’t meet Operational Resilience standards. Kind can help make sure you don’t become one of those firms, with the use of expert contract talent playing a Critical Friend role and running your organisation through stress tests to confirm you’re meeting and exceeding all Operational Resilience standards, and setting out what you need to remedy if you’re not.
The FCA Business Plan covers a lot of ground, touching on a diverse array of focal points for the coming year, but all with the end goal of protecting customers and ensuring Financial Services firms are operating honestly and effectively. I know that’s something we all believe in and are striving to achieve – and Kind Consultancy can help make sure your regulatory journey over the next 12 months runs smoothly.
For a confidential conversation, get in touch on 0121 643 2100 or e-mail me on selena@kindconsultancy.com
Selena Tye