Context
The ABI’s response to the FCA’s proposed reviews is generally supportive, but it has taken the opportunity to make a further point about the FCA’s enforcement proposals published earlier this year. In addition, the ABI has commented on the Bank of England’s findings on the PRA’s new secondary objective.
Key points to note and next actions
The ABI has said that the enforcement transparency proposals “…have the potential to knock international confidence in the UK as a good place to do business…”. The ABI is urging the FCA to “…continue its work to embed the objective into its thinking and to work in partnership with industry on the best ways to help the UK financial services industry meet its full potential…”. The ABI appears not to support the FCA’s enforcement transparency proposals.
The ABI appears supportive of the PRA’s efforts in relation to its new secondary objective, but also supports the Bank of England’s recommendations for how the PRA can make even more progress towards this objective. The recommendations are across four main themes:
- Clarifying the PRA’s vision and desired culture for supporting competitiveness and growth, including how it will affect policymaking and the culture and behaviour that the PRA wants.
- Ensuring staff across the PRA have a consistent understanding of the new objective.
- Harnessing intelligence from inside and outside the Bank.
- Refining transparency and oversight mechanisms to build trust in the PRA’s approach.
The FCA could, similarly, consider an external review of its enforcement transparency proposals and its proposed approaches to rule simplification and competitiveness. The headline themes outlined by the Bank in its report to the PRA would be relevant.