“Regulation today, regulation tomorrow…” Chris Cummings Director AMI

Agenda Regulation, regulation, regulation Don’t panic Do do… Last minute checklist Over the next wave…

Regulation, regulation, regulation Europe HMT DTI OFT HM C&E “It is a truth, universally acknowledged, that a market going through regulation must be in need of more…” FSA FOS FSCS The Courts

Do do… FSA’s objectives: To maintain market confidence in the financial system To promote public awareness of the financial system To provide consumer protection To reduce the opportunities for financial crime FSA’s approach: Risk based approach Emphasis on systems & controls Formal control structure in all areas

Last Minute Checklist Internal controls: PII levels mortgage and protection levels Capital adequacy Regulated business plan SYSC requirements Inducements systems Senior management team Staff training on regulation NILGI

Last Minute Checklist Customer facing: New business process reviewed “independent” - fee option whole of market? Introducer procedures Existing customers contacted ToB letters reviewed: on-going contact customer opt-in data protection IDD KFI provider confirmed Suitability letters

Last Minute Checklist Customer facing: Financial Promotions reviewed transitional arrangements Record keeping requirements Systems to manage non-regulated business Scripted Q&A Complaints procedure: Complaints procedure reviewed Training and competence: Focus on on-going competence requirements

What we expect Willingness to listen to industry initiatives: – PII – Qualifications Easy to do business with A working relationship between industry and regulator: a social contract? AMI expects: Catch our breath Room to breathe Co-ordination “Getting the bad guys” “Hidden agenda” No retrospection Costs of regulatory bureaucracy

Over the Horizon FSA M&GI bedding in FSA themes: Financial Promotions Taking an interest KFIs Responsible lending Policing the perimeter Treating Customers Fairly Regulatory Reporting Issues Ombudsman Home Reversions Exam review Europe: ISD; DMD etc 30 CPs in CPs in 2005 PI – capacity and cost Buy to let Events, dear boy, events…

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