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Our blog explores the latest issues in financial services risk and regulation.

16 October 2017

The ever increasing cost of CASS…and how technology can help

CASS has undergone huge changes, not least in the last 2-3 years with an overhaul of the rules through PS14/09 and the introduction of the FRC Assurance Standard in 2016. The FRC Assurance Standard led firms to thoroughly analyse their end-to-end CASS relevant processes and controls, with most identifying significantly more key controls than previously documented.

03 October 2017

How can you use your investment in Solvency II to implement IFRS 17?

By Anthony Coughlan Blog snapshot Insurance companies can use some models, systems and processes developed for Solvency II for IFRS 17. It is important to understand the differences between Solvency II and IFRS 17, not only so you know the scope of developments required, but also so you can manage...

27 September 2017

How to handle consumer credit complaints the right way

By John Coley and Tessa Norman Consumer credit firms could be forgiven for expecting a break in regulatory activity after a busy summer. In July alone the Financial Conduct Authority (FCA) published consultations on consumer credit affordability guidance, staff remuneration and extending the Senior Managers and Certification Regime to all...

22 September 2017

How IFRS 17 impacts CSM - Actuaries vs Finance

By Alwin Swales Blog Snapshot: The contractual service margin (CSM) is a significant part of IFRS 17 How are insurance companies factoring this into their IT strategy? As all insurance companies are probably aware by now, the introduction of IFRS 17 comes with many new requirements. One of these new...

13 September 2017

Client Asset oversight … when one becomes two

By James Steele-Perkins and Rob Anderson The Financial Conduct Authority (FCA) recently consulted to extend the Senior Managers and Certification Regime (SM&CR) to all sole FCA regulated firms. While wide ranging in scope, there are some particularly interesting Client Asset (CASS) requirements which firms need to consider, subject to the...

11 September 2017

The future of compliance: How a new breed of technology is changing the way we manage compliance

By Mark Gossington Regulatory Technology (or RegTech for short) is one of most exciting developments to have emerged from the FinTech sphere in recent years. The Financial Conduct Authority describes RegTech as “the adoption of new technologies to facilitate the delivery of regulatory requirements.” As regulatory compliance has become more...

06 September 2017

Learning the lessons from the Senior Managers Regime

By Sarah Isted Over recent weeks, I've been asked by a range of clients and colleagues about the lessons learned from the introduction of the Senior Managers Regime (SMR) in the UK. These questions have been driven by two developments. Firstly, in the UK, the Financial Conduct Authority (FCA) is...

05 September 2017

How do you define vulnerable customers?

By Andrew Strange and Tessa Norman What does a vulnerable customer look like? Following the FCA’s business plan, published in April, it’s a question many firms will be reconsidering. It’s especially important given the FCA highlighted vulnerable customers as one of its six-cross sector priorities for 2017/18, saying it’s concerned...

10 August 2017

Tracking down unprofitable parts of your business with IFRS 17

By Nick Wilks Blog snapshot Many insurers view regulation as adding complexity and cost. Analysing data and tracking performance will help identify unprofitable business. Management can then make better informed strategic decisions to retain and generate profit. Regulation often causes a grimace on the face of many of my clients...

Joining the dots in asset management: SMR and the market study

The Financial Conduct Authority’s (FCA) Asset Management Market Study and the extension of the Senior Managers Regime (SMR) to all FCA regulated firms - while both topics are separately initiated, increasingly the interlinkages make considering either in isolation challenging for firms.

09 August 2017

Brexit in Financial Services – the need for transition

By Nick Forrest In the first of a suite of three articles, we explored the challenge of Brexit for financial service firms. We now look at the timescale required for implementing Brexit and our next article investigates the pragmatism necessary to avoid major market disruption. Bank transformation programmes are complex,...

08 August 2017

What should CASS mean to the second and third lines of defence for investment firms?

By Brandy Rosel and Irfan Elias Changes in the Client Money and Assets (CASS) regulatory landscape, such as the Financial Reporting Council (FRC) Assurance Standard and MiFID II, have created more business risk and therefore more challenges for Risk, Compliance and Internal Audit functions as they work to meet business...

03 August 2017

Senior Managers and Certification Regime: Be prepared

The proposals to extend the Senior Managers and Certification Regime (SM&CR) to all firms regulated by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA), will affect around 50,000 firms. Business preparations should start now.

Consumer credit affordability: clarity at last?

By John Coley Consumer credit firms have been eagerly awaiting the Financial Conduct Authority’s (FCA) consultation on changes to its rules and guidance on assessing creditworthiness in consumer credit, published this week. The FCA states that its main aim is to provide greater clarity for firms in how they should...

19 July 2017

Are your customers ready for PSD2?

By Jonathan Turner and Megan Charles Ensuring customer payment transactions are secure is one of the primary objectives of the revised Payment Services Directive (PSD2). The European Commission (EC) hopes to do this by requiring payment service providers (PSPs) to apply Strong Customer Authentication (SCA) as a security measure. But...

14 July 2017

What’s on the PRA’s agenda for 2017/18?

By Conor MacManus The Prudential Regulation Authority (PRA) has set out its priorities for 2017/18 in its business plan. Brexit features heavily in the PRA’s priorities for the period as the regulator prepares to implement the UK regulatory framework following the UK’s departure from the European Union (EU). But it...

13 July 2017

UK Re/Insurers - Have you considered what Brexit means for your ratings?

As insurers firm up their Brexit structures, attention will turn to the broader business, operating and finance model impacts. However, what about the prospective rating of your potentially newly created EU subsidiary?

12 July 2017

How will MiFID II impact the role of those responsible for CASS?

By Brandy Rosel and Irfan Elias The Financial Conduct Authority’s (FCA) MiFID II policy statement (PS17/14) released last week contained over 40 pages of changes to the FCA’s Client Assets sourcebook (CASS). This is the FCA’s final policy statement setting out the rules for their implementation of MiFID II. The...

06 July 2017

A diverse approach to treating customers fairly

By Katy Bennett and Tessa Norman Following the Financial Conduct Authority’s (FCA) business plan in April, firms are expected to focus on their approach to vulnerable customers this year. The focus on identifying and improving the treatment of vulnerable customers was the only new priority introduced by the FCA this...

29 June 2017

Technology: Bringing your biggest Operational Risk exposure in from the cold

By David Lukeman and Steffan Dutch The risks associated with the reliance on technology are significant and increasingly complex to manage. The threats the technology is exposed to are increasing in frequency and sophistication. European Banking Authority (EBA) guidelines on the assessment of Information and Communication Technology (ICT) risk under...