The start of 2015 is in many respects like the start of any other. People approach it with fresh hopes and dreams, and there’s the prospect of new starts and exciting resolutions.
There’s no doubt that in the financial services industry, this will be another interesting and possibly energising year. Developments in both regulation and the economy bring about the possibility of new opportunities. There’s also the prospect of continued growth as the economy hopefully continues to improve. The possibility of a change in government may well shake things up too.
I am certain of one thing however. This will be a challenging year from the point of view of dealing with regulatory change; not just in the UK but from Europe too. I know this can be said of every year, but for 2015, we know that there is a certain amount of change going to happen, because we were given plenty of warning in 2014.
Many of the issues were written about in last year’s blog posts, but to start afresh, here’s a recap of some of the things that are in store for 2015.
Take pensions first of all. April 2015 sees the biggest shake up in a very long time in the way that pensions operate. Arguably, this will be much bigger than the simplified tax rules introduced in 2006. The FCA and the Treasury have set out their stall in terms of the support that will be offered to the public in the form of the Guidance Guarantee, and firms have now got near-final rules from the FCA to help get their houses in order.
January 2015 brings the realisation that there is not long before 5 April 2015 to make all the necessary changes to systems, processes and communications. At the same time, those firms wishing to develop new propositions to offer their customers have a race against time to get to market.
The FCA will bring about more changes this year that we already know are coming. Firms operating contract-based workplace pensions will need to set up Independent Governance Committees by April, and the rules are due to be published shortly.
We can also expect the timetable for the proposed changes to the regime for approved persons in the insurance sector, and the proposed Senior Insurance Managers Regime from the PRA. Non-executive directors in both banking and insurance sectors will, in addition, know what’s required of them, probably before the end of the first quarter.
The FCA will also ring the changes with regard to complaint handling. There will be restrictions on the ways that firms charge customers who telephone them, as well as fundamental changes in the ways in which complaints are both resolved and reported. Firms will also be under more pressure to focus on appropriate customer outcomes rather than just follow the rules to the letter.
The banking sector has its hands full as well, particular with regard to the changes required to ring-fence the retail activities in the largest banks. This is something of a slow-burner in terms of regulatory deadlines, but those banks affected will already have submitted their plans to the regulators. Although they have until the start of 2019 to implement the changes, this is likely to be a long and ongoing piece of work for these banks, requiring many different internal legal and governance restructures.
Turning to Europe, this is the last full year for insurers to get ready for the Solvency II regime. This will be a busy year as firms get to grips in particular with the new reporting requirements, which are due to start in the third quarter of this year. Developments across all three pillars have to be finalised this year – there will be no more extensions.
There are also some major EU developments with slightly longer timelines, but which require work to be done this year. The next round of changes under the EMIR regime, in terms of the introduction of mandatory clearing for certain classes of Over the Counter Derivatives, are likely to start in 2016. Not forgetting MiFID II of course, which is now less than two years away, and has a fixed implementation date.
Objectives and Training
January 2015 also sees the start of the objective-setting process in many firms; not just individual objectives but strategic ones as well. In many firms, individuals will see their personal requirements stemming from what the firm needs to achieve as a whole during the year. Dealing with regulatory change is likely to be a core component of that strategy.
Alongside objective-setting comes personal development planning. The amount of change taking place this year (and I don’t believe that I’ve covered anywhere near all of it) means that training schedules may need to be quite heavy.
This is the perfect time of year to start thinking about structuring training plans, and to consider how much benefit can be gained from utilising external training sources. The sheer volume and complexity of change means that there is a strong case for making the most of seminars, conferences, discussion groups and qualifications to name but a few, to maximise the value derived from training budgets.
So, while the year gets going, now is a perfect time to look at what opportunities are available and structure training plans, before the pressures of work inevitably start to build.
The growth that Industry Events Online enjoyed during 2014 means that it is now a better place than ever to make that fresh start for the new year.
By Martyn Oughton a Professional Member of the International Compliance Association (ICA). Martyn now writes a regular blog for Industry Events Online focusing on the importance of training in all aspects of compliance. Read Martyn's other publications at Martyn's Writers' Residence website.
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