Regulatory Timeline: Culture
Status: Ongoing
Regulator: FCA
Culture, Diversity & Inclusivity covers a broad range of topics, but the one that seems to be exercising the regulatory minds most at the moment is the topic of conduct, or more-precisely “non-financial misconduct”.
The FCA and PRA issued joint Consultation Papers on Diversity and Inclusion back in Q3 2023, with the feedback period ending in December 2023. A formal written ‘notice to provide information’ on non-financial misconduct, issued on 6th February, required firms to sbmit additional information as part of a sector-wide information gathering exercise. Final regulatory requirements are expected to be published in a Policy Statement in H2 2024 with firms then given 12 months after publication of the Policy Statement to prepare. All FSMA firms with a part 4A permission will be in scope, with additional requirements for firms with 251 or more employees. The PRA proposals apply to Solvency II firms, including third-country insurance branches, again with some limitations for smaller firms.
This timeline provides key dates in the regulatory calendar and links to ICSR articles and webinars on the subject. If you would like to discuss any aspects of Culture, please contact us.
FCA Response To House of Commons Treasury Committee’s ‘Sexism in the City’ report
The FCA has responded to the Treasury Select Committee report and confirmed it will prioritise proposals that tighten expectations on firms to tackle misconduct.
UK Parliament: Treasury Select Committee Report Published: "Sexism in the City"
The Treasury Select Committee published its report to the Government
Speech: The hallmarks of a future-fit workforce
Speech by Emily Shepperd, Chief Operating Officer and Executive Director of Authorisations at TheCityUK and Financial Services Skills Commission Future Skills Conference.
FCA Letter: Notice to provide information in relation to incidents of non-financial misconduct
The FCA have written to firms requesting information related to incidents of non-financial misconduct as part of a sector-wide information gathering exercise. All regulated Lloyd’s Managing Agents & London Market Insurers (including P&I Clubs) and Lloyd’s and London Market Insurance Intermediaries (and Managing General Agents) are required to respond.
ICSR Article: Diversity & Inclusivity - Will regulatory action drive a change in direction for the industry?
In September 2023, the PRA and FCA released co-ordinated Consultation Papers on Diversity & Inclusivity in the Financial Services sector, building on the previous Discussion Paper from July 2021. Niki Underwood looks at what the Consultation Papers cover.
FCA Consultation Paper released
FCA: CP23/20 Diversity and inclusion in the financial sector – working together to drive change will require all FSMA firms with a part 4A permission to meet a minimum standard, with additional requirements for firms with 251 or more employees.
PRA Consultation Paper released
PRA: CP18/23 Diversity and inclusion in PRA-regulated firms applies to Solvency II firms, including third-country insurance branches, again with some limitations for smaller firms.
ICSR Article: Is 2023 The Last Chance Saloon For Insurance Firms To Fix Their Culture?
Negative headlines featuring toxic cultural behaviour within the insurance market make painful reading for our industry. In reality though, the salacious nature of those headlines has masked what are far more deep-seated cultural issues that need to be addressed. Niki Underwood takes a look at the issue of culture for insurance firms in 2023.
FCA, PRA and Bank of England set out plan to improve diversity and inclusion in regulated firms
The FCA and PRA have issued a joint discussion paper on diversity and inclusion in the financial sector. It raises some important issues for insurance firms to consider as they strive to create a resilient industry that reflects those it serves.
FCA Supervision Strategy Letters Issued - Culture features strongly
The FCA has issued Supervision Strategy letters to various groups of firms. These documents highlight specific areas of concern around culture in certain segments of the market from the regulator and indicate what firms should be doing.
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- The FCA view of the key risks of harm to the firm’s customers or the markets they operate in;
- Outlines the FCA expectation of the SMF and the firm, including how they should be mitigating the risks identified;
- Makes it clear firms should consider to what extent their firm presents such risks and their strategies for mitigating them.
The FCA say: “When we contact your firm, we will expect you to be able to explain what you did in response to this letter.” Firms should have a clearly document response to these letters.
The following letters make specific reference to culture:
Culture reviews an increasing focus for firms
ICSR completes culture reviews for a number of insurers and Lloyd’s Managing Agencies in 2020.
ICSR Article: The Regulator’s Approach To Culture: A Senior Managers Perspective
Kenneth Underhill looks at the increasing numbers of reviews of businesses and assessments of their culture most commonly as a result of regulatory interaction.
FCA Webinar
FCA webinar: leading healthy cultures in a post-Covid world
ICSR Article: Setting The Right Insurance Culture
Justin Ward looks at the importance of culture in an insurance organisation.
FCA: Business Plan 2020/21 released - including reference to culture
The FCA Business Plan for 2020/21 announced a specific focus on certain cross-cutting peices of work, including culture.
Discussion Paper released
DP20/1: Transforming culture in financial services – driving purposeful cultures
FCA Webinar
Webinar: using assessment as a tool to understand culture. The FCA explore how approaches to assessing firm culture can contribute to greater understanding and management of culture in financial services.
Lloyd's Culture Survey - Results Announced
Following a number of high profile cases, Lloyd’s conducted a major peice of research to understand the issue of culture in the market.
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The 5 key elements announced are:
- A gender balance plan;
- Standards of business conduct;
- Speaking up;
- Wellbeing;
- A Culture Dashboard to closely monitor progress in the Lloyd’s market.
FCA Podcast
Inside FCA Podcast: Interview with Jonathan Davidson and Jayne-Anne Gadhia on Culture and SMCR. Executive Director of Supervision for Retail and Authorisations, Jonathan Davidson, and guest Jayne-Anne Gadhia talk to Ozge Ibrahim about the importance of achieving a healthy culture in financial services, and embedding the Senior Managers and Certification Regime (SMCR).
FCA Discussion Paper released
DP18/2: Transforming culture in financial services
