The FCA has published a Discussion Paper on operational resilience. Although at first sight this would appear to be aimed at large financial institutions, it is worthwhile reading for all firms.
The Discussion Paper explains why operational resilience is relevant to the supervisory authorities’ objectives, why it should matter to firms and their senior management.
The interconnectedness of the Financial Services industry and its increasing reliance on complex technology and shared infrastructure creates risks as well as benefits.
Operational resilience failures, including those caused by cyber-attacks and technology failures, pose a risk to firms ability to provide their services and can cause harm to consumers.
Disruptive events are bound to happen so all firms need to plan for these eventualities, be able to absorb the shocks, and maintain or quickly resume the business services they provide to consumers.
Preparing for BREXIT
BREXIT is generally considered to be a potentially disruptive event that firms will need to deal with in the near future. The FCA has published some high-level guidance for firms.



Pension Transfer charging
Alistair MacDougall Compliance abridged, FCA, P1, Pension, Pension Transfer, PI, transfer
Policy Statement PS 20-06 stated that a firm providing pension transfer advice “… may also not charge less than it would charge for investment advice of the same value”. That seems clear enough, but the rule that gives effect to this statement is subtly different. COBS 19.1B.7 states: “A firm should not charge less […]