Context
The FCA has updated its Skilled Persons reviews web page to include links to the Q2 2024/25 and Q3 2024/25 data publications. These two periods cover July to December 2024. If the FCA is concerned about aspects of a regulated firm’s activities, or wants further analysis, it can commission a view from a third party (known as a ‘skilled person’).
Key points to note and next actions
The Q2 2024/25 data:
- 14 reviews were commissioned in Q2 (two of which related to the insurance sector), the same as for Q1 (of which six were insurance).
- One of the reviews was commissioned under the FCA’s power to contract directly with a Skilled Person.
- 11 of the Q2 reviews related to ‘Portfolio Supervision’ firms (so firms with no dedicated Supervision contact at the FCA), with six relating to financial crime and three relating to controls and risk management frameworks.
The Q3 2024/25 data
- 13 reviews were commissioned in Q3, two of which related to the insurance sector.
- Two of the reviews were commissioned under the FCA’s power to contract directly with a Skilled Person.
- All 13 reviews related to ‘Portfolio Supervision’ firms (so firms with no dedicated Supervision contact at the FCA), with a fairly even spread across four review categories:
- Governance, accountability, strategy – 2
- Controls and risk management – 3
- Conduct of business – 3
- Financial Crime – 5
One and possibly more of the insurance reviews were for product governance failings, and this period coincides with the thematic report issued in August 2024 on the subject. The bulk of skilled person reviews are for Portfolio Supervision firms, so the message to firms is that “you are not too small to have a skilled persons review”.