Consumer duty  

Consumer duty requires shift in culture, says FCA

“This includes consideration of honesty, integrity and reputation,” she said.

“Individuals have been struck off for failing to meet the threshold of being fit and proper after being convicted of offences including holding child pornography, sexual harassment, and serious violence. 

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“Not disclosing arrests or convictions can also lead to a ban.

“One executive received a life-long ban from us after being exposed as one of the country’s most prolific rail fare dodgers.”

She explained that the FCA has undergone its own cultural shift in recent years after acknowledging the criticisms about the time taken in authorisations.

Since then, it has moved to slash queues by 60 per cent.

“We are piloting an approach to application forms and other data-driven tools, with user experience as a major influencer to speed up our processes - without diminishing the thoroughness of our checks,” she said.

“Ultimately, we are preventing serious harm, setting and testing higher standards, in order to promote market integrity, protect consumers and promote effective competition.”

Shepperd said her background in financial services, over decades, means that the moment she joined the FCA, she wanted the regulator to develop a stronger sense of the markets it served, understanding the impact of the approach it took to its internal operations and being clear in the dealings with firms in order to give certainty. 

“At the same time, our consumer facing call centre needed to be integral to the intelligence map we built across the UK that enables us to better understand developing areas of concern,” she said.

“I wanted to build that client-centric muscle, and you can see the results.

“Sometimes regulation can be perceived as slow, but in the last few years we have adapted and responded.”

Recruitment of bad apples

Another area where the FCA is focusing supervisory efforts is tackling misconduct in wholesale markets.

“We want firms to do their best to stop it from happening in the first place, so that means being aware of any past misconduct of new recruits,” she said.

“The best predictor of future behaviour is past behaviour after all.

“Wholesale brokers have told us it is all too easy for individuals who have been involved in misconduct to move from one firm to another, with few questions asked at the new firm. These individuals can become ‘rolling bad apples’, with their misconduct continuing.”

The City watchdog said it wants firms to take their regulatory referencing far more seriously. 

“If necessary, they should extend probationary periods, add extra monitoring or restrict activity.”

Shepperd said new employers must satisfy themselves that the person they’re hiring to hold an official senior management function or certified function is fit and proper and not simply rely on the say so of a former employer.