5. Engage with the consultation
The FCA is welcoming feedback by March 20 2024, so now is the time to voice concerns and thoughts on the proposals.
We would therefore urge firms to engage with their industry association to ensure involvement in coordinated responses, particularly those that provide views on the proportionality of the rules – a specific point the FCA will be looking at closely.
As part of the proportionality discussion, firms should be providing feedback on the extent to which these proposals will take focus away from providing good consumer outcomes for the sake of getting internal infrastructure – ie systems and processes – prepared for implementation. Because, when it comes down to it, the regulator wants firms to be concentrating on creating a well-run business that puts customers first.
No doubt the proposals may be daunting to some, particularly with the financial requirements attached, but, as stated previously, the best advice that can be heeded at this point is prepare, prepare and prepare some more.
The work that is put in now will only reap rewards upon implementation and ensure firms remain out of the red, which, in this instance, will involve the FCA stepping in with automatic restrictions on the sale of products and services.
Linda Gibson is head of regulatory change, EMEA at BNY Mellon Pershing
