The FCA has published the fourth edition of its plan for upcoming work – a key indicator of where the FCA’s attention is going to be focussed across the next two years. An updated Grid is published twice a year and, at 45 pages, this is again a detailed document containing a significant number of initiatives impacting all sectors.
Of key interest to many firms in the insurance distribution sector will be planned further FCA and HM Treasury work on the Appointed Representatives regime, a cross-sector initiative with an FCA Consultation paper planned for this month in which the FCA will be consulting on policy proposals to enhance its rules for principals with Appointed Representatives. This perhaps indicates changes to rules in relation to Principal firm oversight rather than the legislative framework of the regime itself.
The Grid sets out the regulatory pipeline so the financial services industry and other stakeholders can understand – and plan for – the timing of the initiatives that may have a significant operational impact on them. The FCA expects the format of the Grid to remain fairly settled, but asks firms to continue to get in touch at FSRIFSecretariat@fca.org.uk if they have any feedback.
This edition of the Grid contains 134 initiatives, a small increase on the 128 in the third edition published in May 2021. The FCA has also published the Grid in the form of an interactive dashboard and an Excel spreadsheet to help users interact with the underlying data. The Grid is organised by sector. It includes a ‘Multi-Sector’ chapter that covers initiatives that span more than one sector.
The sector specific chapters cover: Banking, Credit and Lending; Payment Services and Systems and Market Infrastructures; Insurance and Reinsurance; Pensions and Retirement Income; Retail Investments; Investment Management; Wholesale Financial Markets.
The multi-sector initiatives (of which there are seven) include financial resilience, operational resilience and conduct (including the Consumer Duty), with a long section dedicated to environmental, social and governance (ESG) related issues, including diversity in financial services (for which a Consultation Paper is planned for the first half of 2022).
The insurance and reinsurance section contains nine initiatives, but only one of these (pricing practices) is likely to impact the insurance distribution population.
Firms should review the relevant areas of the Grid publication depending on the financial services sectors they operate in, and should be aware of where the Regulator’s ongoing gaze will fall.