Well that’s 2023 just about done. Out with the old and in with new as they say, but what’s gone and what can we look forward to?
For all sorts of reasons, 2023 has been another year where a lot has occurred in 365 days. So what did happen?
Lots of things, like…
- In January Croatia replaced the Kuna with the Euro, and after the war in Ukraine escalated, the Doomsday Clock was set to 90 seconds to midnight.
- Sales of vinyl in the US exceeded CDs for the first time since 1987 – sometimes the old stuff really is still better
- Thor the Walrus visited the East Coast of the UK. Apparently he’s now a ‘C’ list celeb and may be appearing in the jungle soon.
- Base Rate went up faster than Elon Musk’s SpaceX rocket (but didn’t come down anywhere near as fast)
- Charlie was crowned King
- There was some political turmoil in Scotland
- There was political unrest in the rest of the UK too. There still is.
- The Lionesses just lost out to Spain in the World Cup
- Stock markets remained unstable
- Consumer Duty went live
- Europe won the Ryder Cup
- The FCA decided to get tough
One constant though, politicians resolutely told the truth. They didn’t? Oh, for goodness sake (or words to that effect).
It’s been turbulent to say the least, but you can’t say it’s been boring.
In compliance world, Consumer Duty, the long awaited big deal from the FCA, landed at the end of July, but for some it seems to have landed softer than a butterfly with sore feet. In fact, some firms have done next to b****r all by the look of things and have seemingly greeted Consumer Duty with the apathy of a teenager being told to put their phone down. Almost like it was a non-event, because nothing has changed in some firms, and probably hasn’t since before RDR. See our other article – entitled ‘Model Behaviour’ – Alistair is in full flow here. And as it’s nearly Christmas we’re providing two articles this week. Ho, ho, ho!
For others, Consumer Duty has been seen as an opportunity and this has resulted in them putting in a great deal of work, looking at their businesses from a different perspective in their continued efforts to do the right thing for their clients. We work with a lot of firms like this and their people are nice to deal with, but others really do need to up their game, because we still see standards that are about as useful as a one legged man in a backside* kicking competition. (*Note the restraint there).
Despite the regulator handing out some eye watering fines for those that didn’t do it properly, it’s still BAU for most at the end of the year, but as we’ve opined frequently of late, the FCA’s approach is becoming far more assertive and they do seem to be targeting firms that they haven’t previously had much contact with and we think that this may well increase. Just this week one of our firms received a lovely email (it didn’t include Christmas wishes though) from the FCA’s Supervision Team requesting a shed load of data, similar to others we’ve highlighted recently. We may be wrong of course, but nobody reading our articles can say that they haven’t been warned.
So what’s on the horizon in 2024?
Well for starters, firms need to produce a board report that explains how Consumer Duty has been embedded. And those Implementation Plans weren’t for show and a one-off. They need reviewing. Didn’t know? You do now.
It hasn’t arrived yet, but the thematic review on Retirement Income Advice is due imminently. It’s taken a long time to produce, so we expect that the findings won’t paint a pretty picture and good client outcomes may have become rarer than rocking horse manure in some firms.
Some are likely to become very much more closely acquainted with a regulator that they thought only paid other firms a call. Ready for that data request? Got the MI? Sure hope so.
The next phase of Consumer Duty, covering closed book products also looms large, with another 31 July deadline. Any of you out there with clients holding old maximum cover whole of life plans? Or still receiving trail from those legacy pension contracts? Better get your skates on.
PS23/16 and Sustainability Disclosure Requirements anyone? Cash balances on platforms? Cash in investment bonds?Then there’s DP 23/5 and the advice guidance boundary to consider, as well as the implications of CP23/24 – Capital Deduction for Redress in the mix.
2024 seems to have a lot in store!
Oh, forgot to mention…
For those readers who weren’t aware, the biggest news of 2023 was of course that it saw the acquisition of ATEB by Thistle Initiatives, and from mid-January onwards ATEB will be rebranded and formally become part of Thistle. This won’t have any real impact for our existing firms of course, but it will give us a shiny new logo and equip us with greater ability to deal with the ever changing and challenging regulatory landscape.
All that remains now is to thank you all for subscribing to ATEB News and for your positive feedback, which is so welcome. We’ll be back with more in ’24!