Horizon scanning for risk managers
Regulators often remind firms that they are expected to learn from all their outputs, so risk manager horizon scanning should not be limited to regulator rules and updates. Their scanning should encompass, for example, consultation papers, speeches, press releases and portfolio letters. It should also consider portfolio letters addressed to other regulated sectors.
Managing risks in a light touch world
We have seen several market cycles and in most cases regulation and regulators are seen as followers, tightening regulation after an event – ‘after the horse has bolted’ if you like. This was certainly the case after the Global Financial Crash (GFC) of 2008/9, which led to expansion and significant tightening of regulation within the financial sector. However, we are now witnessing a substantial swing in the regulatory pendulum leading to some CROs fearing a new ’race to the bottom’.
The FCA continues to drive for consumer protection
The FCA final guidance (FG24/2) has just come into force, replacing and building on the earlier Covid Tailored Support Guidance, and further protecting the ongoing needs of borrowers in financial difficulty.
The fines keep coming….
Less than a month ago we wrote about the ‘cost of non-compliance’ exceeding £1bn for poor arrears handling, through FCA fines and redress. Since then, we have seen yet another one. It is clear to us that the FCA is fining firms to drive home the need for a behavioural change in the way lenders treat their customers and arrears strategies.
FCA fines approach £1bn for arrears breaches
Following the most recent FCA lender fine, conversations with our business partners have been ‘off the scale.’ Everyone is shocked that collection teams are still getting it so wrong. FCA fines for the poor treatment of arrears and vulnerable customers is nothing new, and although they appear to relate to historic cases, be in no doubt, everyone is starting to question their own policies and procedures – again.
SRT and Basel 3.1 – are you ready?
We are often asked by our clients to comment on market trends and movements. Significant Risk Transfer [‘SRT’] is currently dominating our conversations, and much of our work, especially our AUP services connected with SRT issuance programmes. 12 September 2024 is a key date that will lead to a seismic market shift – are you ready?
Niche lenders, back in the driving seat?
The UK lending market is in the grip of a seismic shift, driven by significant M&A activity, choices being made by laggards in the digital transformation race and the regulatory impact of tightening capital requirements.
Mortgage Charter Independent Oversight
The FCA has released its first report analysing the impact of the Mortgage Charter. Launched exactly a year ago, the Charter received some negative industry comment, with a number of lenders suggesting that they already had robust forbearance measures in place and it wasn’t needed. However, on any measure, the FCA data shows positive consumer outcomes.
FCA complaints – a worsening picture
Increasing numbers of complaints, and the lack of real resolution by firms, is not new news, but regulators are becoming impatient for change. After years of TCF and more recently Consumer Duty implementation, it is not surprising that they are questioning when they will see improved outcomes. So why are regulators becoming increasingly tired with the lack of progress and what is behind their increasing frustration?
Another FCA warning shot
The most recent FCA ‘strategy letter’ on consumer lending is one of the most detailed we have seen, and it focuses on three portfolios; high-cost lending, mainstream consumer credit lending and credit unions. This is an unusual step for the regulator, as it normally issues separate letters to each portfolio. However, on this occasion there is a combined warning as it highlights common potential consumer harm issues in each portfolio.
