A Court has found in favour of the lender in a case brought by a couple who entered into a 5 year interest only loan through a broker, which they met repayments on but were ultimately unable to repay the capital. The claimants said that the lender, Godiva, should have realised that a claim on the […]
BEIS has published its response to its consultation on the reform of Limited Partnership law. It has confirmed new measures, applicable to all limited partnerships in the UK (and, for Scottish Limited Partnerships, in addition to the beneficial ownership reportingrequirements previously introduced), to: require anyone registering a Limited Partnership to show they are registered with an […]
FCA has updated its website to show the forms that now apply to insurers, who have become subject to the SMCR from 10 December.
FCA has published the results of its study of cyber-resilience and security in 20 asset management and wholesale banking firms. Its review comprised firms of varying size, scale, operating models and geography. The review comes with many caveats, but the key messages include: Boards and Management Committees still have limited familiarity with the specific cyber-risks […]
The Upper Tribunal has ruled on an application by Mohammad Prodhan, former CEO of Sonali Bank (UK). Mr Prodhan contended that FCA was time-barred from taking action against him. He also applied for a direction for his anonymity in proceedings of the Tribunal and the FCA. Mr Prodhan alleged that FCA had not issued him with a Warning […]
Companies House has announced it now carries on additional checks on certain applicants for registration, to guard against designated persons using economic resources such as companies in an attempt to get round sanctions restrictions. From 12 December, Companies House will check applications from UK companies, European Companies, LLPs and SLPs, to assess the name, address, […]
The Charity Commission has warned charities that operate in Syria or Turkey of the dangers of aid passing through the Bab Al-Hawa crossing. There have been reports that the crossing is under the control of Al Qa’ida which means that charities and their partners that use it could inadvertently be funding that organisation and thereby […]
FCA’s latest quarterly consultation proposes rules that: amend SUP 16 to address FCA’s concern that it does not always hold accurate “firm details” by requiring an annual accuracy check and removing the option some firms currently benefit from to update details other than using Connect; and add the Association of Accounting Technicians to the list of bodies […]
FATF has published the long-awaited mutual evaluation report on the UK’s measures to combat money laundering and terrorist financing. The report notes that, because of the exceptionally large funds flow through the UK financial sector and the risks that some of these have links to crime and terrorism, there is a strong understanding of the […]
FCA is consulting on permanent rules to restrict the marketing, distribution and sale of CFDs and CFD-like options to retail consumers. The proposals are similar to the ESMA temporary measures, but FCA wants also to cover closely substitutable products and are proposing some different leverage limits. FCA feels the action is necessary because of constant […]
The European Commission has launched a review of the Distance Marketing Directive (DMD) to assess whether it is relevant, effective, efficient, and in line with other EU legislation. The review follows an announcement by the Commission in its 2019 work programme, that it would carry out an evaluation of the DMD in line with the better regulation principles. […]
ESMA has published the advice it received from the Securities and Markets Stakeholder Group on amending the PRIIPs KID. The group fully supports the principle of the KID but is disappointed that there are proposals for change so soon after firms spend significant resource to implement the original requirements and also that the consultation period […]
The European Parliament and the Council of the European Union have reached a provisional political agreement on the banking package of reforms that will result in CRD V/ CRR II. Proposed measures include more risk-sensitive capital requirements, in particular in the areas of market risk, counterparty credit risk and for exposure to central counterparties, and […]
The FCA has published the outcome of its thematic review into the treatment of customers with long-term mortgage arrears. While in general it found that firms treated such customers appropriately, it did note areas for improvement and inconsistencies in management practices. The FCA recommends that firms that offer or administer mortgages should read the review, […]
FCA has published the key findings from its recent information gathering exercise on pension transfer advice. This year it has collected information from an additional 45 firms and visited 18 of them. It found less than half the advice given was suitable and FCA is very disappointed that firms are still failing to give suitable […]
BIS has published a report on range of practices relating to cyber resilience. The report focuses on four areas of cyber resilience: governance and culture risk measurement and assessment of preparedness (both in preventing and recovering/learning) communication and information sharing interconnections with third parties. Drawing on competent authorities responses, exchanges between international experts and input […]
The EBA has published final Guidelines on the exemption from the fall back mechanism requirement under the RTS on Secure Customer Authentication and Common and Secure Communications (Commission Delegated Regulation (EU) 2018/389) (SCA & CSC RTS). This exemption applies to account servicing payment service providers (ASPSP) who meet the four conditions sets out in the […]
The Competition and Markets Authority (CMA) is consulting on its proposed Annual Plan, which sets out its plans and priorities for 2019 to 2020. Subject to the outcome of the Brexit negotiations, the CMA plans to give greater priority to potential market studies and investigations as it considers future work. The themes which it proposes should carry […]
ESMA has added to its EMIR Regulation Q&A document. The updated question relates to Article 41 of EMIR, on margin requirements.
FCA has published a decision notice setting out its proposal to find Mohammad Prodhan, the former CEO of Sonali Bank (UK) Ltd £76,400 in relation to the bank’s AML systems and controls. Mr Prodhan was responsible for the establishment and maintenance of effective AML systems and controls and FCA considered that between 2012 and 2014 […]
MEPs in ECON have voted through the proposals for changes to the rules on cross-border investment fund distribution. As part of the vote, they stipulated that marketing communications should be clearly identified as such and should include a detailed note of risks, investors’ rights and redress mechanisms. On pre-marketing, ECON defined the key point as […]
The FCA has today published a new webpage on requirements in its Handbook that apply to firms distributing insurance. The FCA says that although it expects firms will have already adapted their processes to take account of the new rules, which came into effect on 1 October 2018, it was calling on them to continue […]
FMLC has noted a number of legal uncertainties in the various draft onshoring legislation relating to investment funds and their managers. In relation to the drafts for AIFMs and Collective Investment Schemes, FMLC has spotted issues with: references to other legislation – and conflict between pin-pointed dates on which terms take effect; the temporary recognition […]
ECB has published its expectations on financial market infrastructures in terms of cyber resilience oversight. Its expectations are based on CPMI/IOSCO guidance and is aimed at providing the FMIs with clear steps on how to operationalise and enhance the guidance as well as providing supervisors with a clear remit for engaging with FMIs and assessing […]
Treasury has made the Sanctions Review Procedure (EU Exit) Regulations 2018. The Regulations, made under SAMLA, come into force on 7 January 2019 and address the mechanics of requesting reviews, variations or revocations of designations made under the Act.
SFO announced that the first DPA, agreed with what is now ICBC Standard Bank plc for breach of s7 Bribery Act, has come to an end after the bank successfully complied with its terms. The DPA lasted for 3 years. Its terms included payment of compensation and disgorgement of profits as well as a fine, and […]
Directors should receive pension contributions in line with the rate given to the majority of the rest of the workforce, according to new Principles of Remuneration published by the Investment Association (IA). The IA has updated its executive pay guidelines in response to investor concerns that companies are not listening, or responding, to shareholders over […]
The Department of Work and Pensions (DWP) is consulting on proposals to create an industry-led system of multiple dashboards which will allow millions of people to access their pension facts and figures from most pension schemes in one place online. The government is proposing that the Single Financial Guidance Body (which will replace the Money […]
The FIN team was delighted to win two awards at the 2018 Compliance Register Platinum awards, including Best Consultancy/Law Firm – Regulatory Compliance. Thank you to those of you who nominated us and those who were there to share the evening with us.
The Treasury Committee has published the Bank of England’s analysis of the Withdrawal Agreement and Political Declaration. The lengthy document explains how the reduction in openness with reduce the UK economy’s productive capacity and generally its short-term rate of growth – and how a disorderly Brexit will exacerbate this. It also notes that the longer-term […]
BoE has published its latest Financial Stability Report together with the results of the 2018 Stress Tests. The Financial Stability Report found that the UK financial system has good resilience to a range of risks, including Brexit – banks could lend in a scenario more severe than the financial crisis and are prepared and strong […]
EIOPA has published draft technical advice to the Commission on the integration of sustainability risks and factors in delegated acts under Solvency II and IDD. The proposed amendments include the addition (in the Solvency II Delegated Act) of a responsibility for identifying and assessing emerging sustainability risks to the risk management function, and including any […]
Following a consultation last year, the FCA has published the ‘FCA Mission: Approach to Authorisation’ and feedback statement. This document includes reference to the introduction of a new range of tools to help firms submit complete authorisation applications. This should minimise the risk that submitted applications will be deemed incomplete and the time for assessment […]
As part of the preparation for a ‘hard’ Brexit, the Treasury has published a Policy Note that accompanies a draft Bill covering in-flight financial services legislation, currently progressing through Parliament. The Policy Note comments that in scope of the Bill are pieces of EU legislation agreed or in negotiation at the point of exit, with implementation […]
FCA has published the results of its survey on tech and cyber resilience, which showed that nearly half of all firms don’t upgrade or retire old IT systems in time, and only just over half say they can measure the effectiveness of their information asset controls. Megan Butler, speaking about the report, said that FCA […]
FCA has published a new modification by consent to allow firms to exclude from their complaints return form those PPI complaints in relation to which the complainant had not in fact bought PPI from the firm. Any firm wanting to take advantage of the waiver must email FCA to apply for it.
FCA announced today that it will be delaying the launch of its Credit Information Market Study Terms of Reference until June 2019. The delay is a result of the FCA having to prioritise the market study on general insurance pricing, which launched on 31 October 2018 but was not originally part of its business plan.
On 22 November 2018, DExEU published the Draft Political Declaration setting out the framework for the future relationship between the United Kingdom and the European Union (“Draft Declaration“). The Draft Declaration puts forward proposals for the future working relationship between the EU and the UK, including a new framework for the financial services market.
On 22 November 2018, Treasury announced it was developing a draft SI for MAR. It proposes that the SI will address: the scope of the regulation; transaction reporting; notification requirements; transfer of functions; and supervisory cooperation and information sharing Treasury also published the Packaged Retail and Insurance-based Investment Products (Amendment) (EU Exit) Regulations 2019; a […]
The Working Group on Sterling Risk-Free Reference Rates (Working Group) has published a communication pack entitled ‘Preparing for 2022: what you need to know about LIBOR transition’. The pack is designed to inform readers about the transition from LIBOR to SONIA and covers the following areas: the problem with LIBOR; why SONIA is the preferred […]
The Plenary of the Financial Stability Board (FSB) has announced the appointment of Randal K. Quarles (Governor and Vice Chairman for Supervision at the US Federal Reserve) as its new Chair and Klaas Knot (President of De Nederlandsche Bank) as Vice Chair, for a three-year term starting on 2 December 2018. Randal K. Quarles will replace […]
The Payment Systems Regulator (PSR) is consulting on its proposal to make general directions requiring payment service providers (PSPs) to implement a Confirmation of Payee (CoP) service. The consultation paper seeks comments on whether regulatory intervention is needed to require banks and PSPs to offer a CoP service to their customers when they make payments using […]
On 20 November 2018, Germany’s Federal Ministry of Finance announced that it had prepared draft legislation to provide continuity of business for UK insurers and banks. The draft legislation referred to as “Draft Act Supplementing the Act on Tax-Related Provisions concerning the Withdrawal of the United Kingdom of Great Britain and Northern Ireland from the […]
ESMA has released a Public Statement on how central clearing is to be addressed in the event of a no-deal Brexit. ESMA supports continued ability to access UK CCPs and has therefore welcomed the decision to adopt a temporary and conditional equivalence decision. It is now working to plan for recognition of UK CCPs in […]
The first Commencement Order under the Sanctions and Anti-Money Laundering Act 2018 has been made. It brings into force the majority of the sanctions provisions in the Act that enable Ministers to make and implement sanctions. The rest of the Act, including the repeal of existing legislation, will be the subject of a separate Order, […]
FCA has published additional proposals on how it will deal with a hard Brexit. The consultation focuses on: more changes to the Temporary Permissions regime; reflecting the new Credit Rating Agency and Trade Repository Regime in the Handbook and FCA’s approach to guidance and forms Key elements of the consultation include: new “cross-cutting” issues that […]
The FCA has published a consultation paper (CP18/35) setting out its proposals to introduce a price cap on rent-to-own (RTO) firms, summarising the feedback to the consultation carried out in May 2018 on high-cost credit (CP18/12) , and its final rules on a point-of-sale ban on extended warranties alongside the sale of an RTO agreement. In its consultation carried […]
Matthew Wagstaff has spoken on SFO’s priorities and resourcing, and the successes of its collaborations with other enforcement agencies, particularly the DOJ. He spoke of SFO’s perception that the s7 Bribery Act offence has been a big success, as has been the ability generally to hold senior management to account. He moved on to discuss […]
In readiness for the UK’s departure from the European Union, Treasury has published further draft statutory instruments including: Financial Services (Distance Marketing) (Amendment) (EU Exit) Regulations 2019: amending the Financial Services (Distance Marketing) Regulations 2004 by removing references to EU/EEA bodies, territories and instruments and replacing the references to the European Consumer Credit Information Form […]
Rob Gruppetta has spoken on FCA’s views on the use of innovation, data and algorithms to help it in its supervision of, and approach to, financial crime prevention. He said that FCA is always open to innovation, but that it should not be approached without scrutiny. He highlighted FCA’s TechSprints (or “hackathons”), one of which […]
EIOPA Chairman, Gabriel Bernardino, opened their 8th Annual Conference today in Frankfurt with his speech on insurance and pensions: securing the future, which is also the theme of this year’s conference. His speech also looked back at EIOPA’s achievements in the last year and discussed their priorities for 2019. The one day conference will look at […]
FCA has published a report looking at how banks and building societies are developing and delivering their commitment to provide prompts to customers. The prompts should increase engagement of consumers with their products and make them aware of switching possibilities and developments in retail banking. The report has identified practices that are helpful, such as […]
The FCA has published a speech by Christopher Woolard, Executive Director of Strategy and Competition at the FCA, delivered at the Regulation of Cryptocurrencies event on 20 November 2018. The speech highlights the key issues identified by the Cryptoassets Taskforce (consisting of the FCA, HM Treasury and the Bank of England) in its report published at the […]
FCA is consulting on policy proposals for its proposed regulatory fees and levies for 2019/2020. Among the proposed changes is a plan to streamline the process of setting consumer credit fees by exemption community finance organisations and credit unions. The other main element of the paper discusses how FCA will raise fees from credit rating agencies […]
At its latest Board meeting, FCA has made changes to DISP and its guidance, effective from 8 November, to confirm that firms must not reject relevant regular premium PPI complaints without considering whether recurring non-disclosure is an issue. Separately, FCA has amended Chapter 13 of IPRU(INV) to require personal investment firms to have PII cover […]
Andrew Bailey has written to Nicky Morgan setting out FCA’s plans for improving accessibility and usability of the Financial Services Register, and updating on its recent consultation on the register of individuals.
The Department for Exiting the EU published a press statement alongside the announcement on 14 November that the UK and EU negotiating teams had reached an “in principle” agreement on the Withdrawal Agreement and an outline of the Political Declaration on the future relationship. It also published the draft agreement, outline declaration and joint statement. […]
ESMA has updated its Q&As on MiFID II and MiFIR, and on the Short-Selling Regulation. The topics addressed by the MiFID II and MiFIR Q&As include making market structures and transparency issues. The Short-Selling Q&A updates a regulatory reference.
FCA has published its review of how firms implement FCA whistleblowing rules. Its review covered a range of wholesale and retail banks. It found several areas of both good and poor practice to comment on, and now urges all firms to review the report and consider what steps they may need to take to improve […]
The latest batch of draft SIs published under the EU (Withdrawal) Act to ensure continuity of legal framework in the event of a no-deal Brexit relate to: Venture Capital Funds; Social Entrepreneurship Funds; and Money Laundering and Transfer of Funds.
In the light of the implementation of IDD, the CMA is proposing to amend the Payment Protection Insurance Market Investigation Order 2011 (Order). Currently, the Order requires PPI providers to send policyholders and Annual Review document, which contains specified information, including a policy summary. The CMA proposes that the Order should mandate that the reference […]
As part of the implementation of the Securities Regulation, which begins to apply from 1 January 2019, ESMA has published: draft regulatory and implementing standards on the contents of applications to register with ESMA as a securitisation repository; Final Technical Advice on fees to be charged for registering and supervising securitisation repositories; further guidance to […]
The ECB has published non-binding guidance for banks on its expectations regarding internal capital liquidity adequacy assessment processes. The guides will be applied from 1 January 2019. These guides updated previous guidance from January 2016, and indicate an intensification of the ECB’s supervisory assessments and an increase in the role of ICAAP and ILAAP in […]
Sir Brian Leveson and Lisa Osofsky (among others) were listed to give evidence to the Bribery Act Committee. They were expected to be asked questions such as: whether a company that self-reports at an early stage should be offered a DPA as a matter of course; the truth in a belief that some of the […]
ESMA has updated its FAQs on the Market Abuse Regulation, adding new questions on trading restrictions for persons discharging managerial responsibilities.
The Financial Stability Board has published a “cyber lexicon“, comprising a set of around 50 core terms related to cyber security and cyber resilience in the financial sector.
ESMA has updated its supervisory briefing for regulators on the suitability requirements under MiFID 2. The briefing covers: when a suitability assessment is needed; information to clients on the assessment; getting information from clients; arrangements necessary to understand products; arrangements necessary to understand the suitability of an investment; suitability report; staff qualifications; and record keeping.
FCA has completed its first financial crime survey. It intends to carry out the survey annually, using the Financial Crime Return. Over 2,000 firms were required to file the return, and FCA looked to establish: the number of customers that pose a higher risk of financial crime: Firms identified 120,000 PEPs and 11,000 non-EEA correspondent […]
The Foreign Affairs Committee in the Commons has launched an inquiry on the future of UK sanctions policy. Given SAMLA’s Royal Assent, the Committee is to look at different options for the UK’s sanctions policy post-Brexit. It is calling for written submissions on several elements of sanctions regimes, including views on the advantages and disadvantages […]
The ESAs are consulting on proposed amendments to the PRIIPs KID. The consultation follows the ESAs’ letter to the Commission on developing guidance on information on investment funds. It also noted the need to make targeted amendments to the PRIIPs delegated Regulation to apply the PRIIPs KID requirements appropriately to UCITS and relevant non-UCITS funds, […]
Hannah von Dedelszen has spoken on how companies that choose to self-report can engage with SFO. She stressed that being open, honest and transparent is the key. she noted some firms operate “smoke and mirrors”, involving admitting some things but hiding more major issues. She said any firm reporting must do so properly. Going forward, […]
ESMA has published a report with draft RTS that would amend the 3 Commission Delegated Regulations on EMIR. ESMA is proposing a limited exemption that would facilitate novation of certain non-centrally cleared OTC derivatives to EU counterparties for a specific time-window in the event of a no-deal Brexit. The proposals would allow novation without triggering the […]
The Treasury Committee in the Commons has launched a new inquiry into consumers’ access to financial services, with a focus on vulnerable customers. Nicky Morgan said the committee will look at FCA’s definition of vulnerability and how practical it is, as well as how financial institutions try to address the problems of financial exclusion and whether vulnerable […]
PRA has published a policy statement to its second consultation on extending the SMCR to insurers. Following FCA’s finalisation of its rules on the extension, PRA now confirms it had no responses to its consultation and has made no changes to the rules it consulted on. As a result, it has now made the rules, […]
BoE, Treasury and FCA have hosted what has now become a regular one day exercise to test the financial sector’s resilience to a major cyber incident impacting the UK.
The Bank of England and Pay.UK are inviting expressions of interest from senior stakeholders who could represent the payments industry on a newly created Standards Advisory Panel. The new Panel will focus on the implementation of ISO20022, but also cover also payments standards for the UK. The deadline for applications is Monday 10 December 2018.
The Law Society has responded to the Law Commission’s consultation on reform of the SARs regime. It says the proposals, in the main, do no more than “tinker around the edges” of the issues. It says some of the more radical proposals, such as adopting a serious crimes approach instead of an all crimes approach, […]
The latest edition of Ombudsman News looks at complaints and trends around pensions. Complaints about pensions make up a very small proportion of all complaints, but as a pension is so important to consumers, FOS has focussed on assessing what it sees as the key rights, and included case studies on complaints involving defined benefit to […]
PRA has fined 2 individuals connected with the Bank of Tokyo-Mitsubishi following its action in 2017 against the bank and MUFJ Securities EMEA. It has fined Akira Kamiya, former Chair of Mitsubishi UFJ Securities International plc £22,700, and fined Takami Onodera, a former NED of the firm, £14,945. The actions occurred before the SMR took […]
Following its consultation in July 2018 on handling complaints about regular premium PPI, the FCA has published finalised guidance that confirms that firms should assess PPI commission disclosures not only at point of sale, but on an on-going basis. The FCA is also consulting on new rules that would require firms that sold relevant products […]
EIOPA has issued a call to action for insurance firms to take steps in good time to ensure they will be able to continue to service policyholders in the event of the UK withdrawing from the EU without an agreement. It notes that UK (and Gibraltar) insurance entities who have cross-boarder insurance contracts should write to […]
EBA has published the results of its 2018 EU-wide stress tests. This year’s test involved 48 banks from 15 countries and generally shows increased resilience and capacity to withstand the shocks the exercise tested. The exercise did not have a defined pass/fail threshold but rather sought to give supervisors a tool to assess banks’ ability […]
The CMA has made a provisional finding that ComparetheMarket includes clauses in many of its contracts with home insurers that breach competition law and could lead to higher premiums for consumers. It says the clauses stop insurers quoting lower prices elsewhere and therefore prevent rival comparison sites and other channels from offering cheaper prices than […]
CMA has published a consultation paper as part of its review of the investment consultancy and fiduciary management services study. The paper contains draft definitions. The proposals define: “investment consultancy service” and “fiduciary management service” The paper also notes that other terms, such as “pension scheme trustees” and “interconnected body corporate” will need separate definition. […]
FCA’s latest Policy Development Update lists a number of publications due before the end of the year: policy statement on regulating CMCs policy statement on RTS and guidelines under PSD2 rates proposals for covering the costs of OPBAS review of permitted links for insurers in relation to Patient Capital and a discussion paper on Patient […]
HMRC has updated its guidance on how it takes civil measures for breaches of AML requirements. The guidance not only sets out HMRC’s approach, which is to promote compliance and prevent non-compliance, but then to respond to any non-compliance in a way that will encourage sustained future compliance but also explains how it will use […]
PRA has updated its “approach” documents in relation to banking and insurance supervision. Key changes to the previous versions include: an update on the changes to supervisory approach following implementation of the SMR and SIMR (and, in the case of insurers, looking forward to the SIMR changing to the SMCR at the end of the […]
As part of its preparation for the contingency of a ‘hard’ Brexit, HM Treasury has published draft onshoring legislation relating to: Payment accounts Financial markets infrastructure insolvency Central securities depositories and Investment funds and managers The changes made under these SIs are unlikely to take effect if an implementation period is agreed.
On 30 October 2018 the FCA announced that it had fined Liberty Mutual Insurance Europe SE (Liberty) £5,280,800. The fine relates to failures in Liberty’s oversight of claims and complaints relating to mobile phone insurance for the period 5 July 2010 until 7 June 2015. According to the Final Notice issued by the FCA, Liberty had entered into […]
On 31 October 2018, the FCA published the results of a thematic review on the pricing practices of household insurance firms. The review uncovered a number of issues on pricing practices. As a consequence, the FCA announced a number of next steps: conducting a market study on general insurance pricing practices; Publishing a discussion paper […]
UK Finance has submitted a note to the Economic Crime enquiry on how to improve the effectiveness of the sanctions regime. It says its members regard SAMLA as a necessary piece of legislation which is largely as expected. It recognises that operating outside the EU framework might lead to greater flexibility, and makes some suggestions […]
FCA’s latest Handbook Notice heralds just one set of rule changes. The changes are to COBS, PERG and examination standards in respect of pension advisers providing suitable advice to consumers about whether to transfer from safeguarded benefits to flexible benefits.
FCA has published its H1 2018 complaints data, which show that firms received more than 4 million complaints in the period. This was a 10% increase from the previous period. Nearly all the complaints were made to 235 of the more than 3,000 firms which recorded complaints. PPI accounted for 42% of complaints, and then […]
FCA has written a “Dear CEO” letter on the duties of SIPP operators in respect of due diligence. The letter refers to the judgement in the Berkeley Burke case and several other pending civil claims, and asks firms to consider the potential implications of these cases for them and their customers. The Berkeley Burke case, […]
The Cryptoassets task force, led by Treasury, has published its report on the UK’s policy and regulatory approach to cryptoassets. The report looks at the policy and regulatory implications of DLT and cryptoassets and comments on the considerable risks as well as the potential benefits. Now the Task force will consult on a number of initiatives, specifically: […]
The Treasury Committee has published the Twenty-Fourth Report of Session 2017-2019 on SME Finance. The Committee highlighted the investigation into RBS’ Global Restructuring Group (GRG), and noted the FCA’s comment that the failures at the GRG might have triggered disciplinary action, had they occurred in a regulated business. The Committee commented that the justification for […]