This month our Director, Dan Waltham interview Gerard Hurley, Chief Compliance Officer at Chip for our latest webinar on the 2020 FCA Business Plan for FinTechs and Consumer Firms.
With COVID-19 having a profound effect on consumers and markets, businesses are facing unprecedented challenges as they try to balance business continuity and the safety of their employees with the interests of customers.
Despite these challenges, the FCA have set out their 2020/2021 business plan, with a focus on progress without undermining the coronavirus response. Whilst most importantly, ensuring that the regulatory burden on firms remains proportionate in the current climate.
We wanted to take a closer look at the business plan, as well as provide an interpretation on what this means for FinTechs and Consumer firms.
Gerard also provided his own recommendations for FinTechs and Consumer Firms, which we have listed below:
- Ensure robust product governance before launch and document it
“Even if it’s just a short call or a meeting, in these times it’s important to understand what the product does, what the risks are from your product, what controls are you going to have in place both upfront and on an on-going basis, as well as making sure you have someone as an owner for any of these actions. Once you launch your product, follow up where you can to make sure those check points are covered and that the data is constantly reviewed”.
- Assess whether your systems and controls are working properly. Do you have sufficient MI (e.g. collections or complaints data) to identify patterns and problems?
“There is no point looking at the same data every month and doing nothing about it. Are you identifying a pattern and a root cause? What are you doing about it?
Having a great relationship with your customer success manager is important. Ask them to look for these root causes within say, “customer complaints” and report that data to you over a period of time. Once you have this data, you should then take appropriate action”.
- Ensure you have a robust Information and IT Security framework – get the message from the horse’s mouth.
“The modern compliance professional has to know a lot more about information and security than they would have had to in the past. Compliance and Information Security must work together. Can you afford for your IT Professionals and Compliance Professionals to not be on the same page? Working under the same umbrella allows for data to be quickly and effectively shared between both disciplines.
- Review your approach to conduct risk, especially vulnerable customers and make sure you document your approach.
“For lenders, it’s important to look at your own policies and training towards working with vulnerable customers. Is it working and have you documented your approach?
- Review whether you can justify your pricing strategy.
"Is the customer getting value? Are they utilising all of the elements of the product that you provide?"
One of the key take-aways from this webinar is about prioritisation.
It’s clear from the business plan, (which is a quarter of the size it usually is) that the FCA are prioritising customers and markets. If the FCA can re-focus and re-prioritise, both large and smaller firms should take note and re-evaluate their own business objectives to meet these new and unprecedented times.
To watch the full webinar, click on the link below and register your details.