Focusing only on delivery deadlines for FCA regulatory requirements could be a costly strategy
The FCA still haven’t confirmed timelines for SMCR/Accountability 2 for all Financial Services Sector firms (we now know insurers will be at the end of the year) and whilst that remains the case it seems that many firms – that will come in scope – are deferring plans and decisions in terms of their response to it.
As we know the actual dates for Accountability 2 will depend on the Treasury finding space to push the required legislation through and – as we also know – the legislative timetable and indeed HM Treasury are rather busy right now – with all things Brexit! Add to this the focus of many firms on MiFID II and GDPR (and in the Insurance sector IDD) and it is understandable that there may be slippage in focus on SMCR/Accountability 2. However, the requirements of all these significant slabs of regulation/legislation share many common requirements and – in particular – T&C implications and obligations. Given the more urgent deliveries around the first two it is worth exploring what these are.