SM&CR – Accountability 2 – the costs of an “appropriate” response
So the proposed details of the Accountability 2 regime are out there and firms now at least have some answers regarding proportionality and the levels of requirement that will apply to them. As before the Consultation Papers’ publication – many firms still appear to be focusing on the ‘least case scenario’ i.e. what is the least they can do to get away with it.
This has to be a worrying attitude and one that just doesn’t cut it with the cultural principles changes that the FCA is looking to achieve across the industry. Instead firms should be focusing on what does good look like and applying the highest practical standards that they can achieve based on budgets and resources available. READ MORE