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Published byNoreen Dean Modified over 9 years ago
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“Regulation today, regulation tomorrow…” Chris Cummings Director AMI
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Agenda Regulation, regulation, regulation Don’t panic Do do… Last minute checklist Over the next wave…
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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
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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
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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
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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
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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
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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
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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 2004 80 CPs in 2005 PI – capacity and cost Buy to let Events, dear boy, events…
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Stand Up AMI: – Insight – Information – Analysis – Industry Voice – Honest Broker – Helpdesk – Information rich website – Regional meetings “Your voice in a hostile world”
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