FCA business plan image
The FCA recently published its 2019/20 Business Plan, whose sector and cross sector priorities are summarised in the annex to this blog together with a timeline of key planned publications and pieces of work.

Key Messages for Firms

In many respects, the plan represents strong continuity with its predecessors.  In particular, we think it significant that the lion’s share of Andrew Bailey’s introduction is given over to the well-established themes of firm culture, treatment of vulnerable customers, and how price discrimination is affecting longstanding customers. In our view, these themes are increasingly being woven into the fabric of the FCA’s day-to-day supervision and wider programme of work, and firms should thus expect increasing scrutiny of them. Other themes such as financial crime, as well as the more recent topics on firm’s use of data and of outsourcing exposure and operational resilience generally, all remain high priorities on the FCA’s agenda.

Notably, however, the FCA is also prioritising two new longer term issues:

(i) The future of regulation, where the FCA says that “as the UK leaves the EU, we believe it is time to review how we regulate to ensure it keeps pace”. This includes looking at how it might apply a duty of care, reducing the regulatory costs faced by small businesses, and the need to respond to regulatory perimeter issues raised by new technologies. This priority was also the theme of a recent speech by Andrew Bailey, in which he stated that, “left to our own devices” the UK would shift after Brexit towards a regulatory system that would “take on board practical experience more rapidly, and…be based more on principles that emerge from experience in public policy and somewhat less on detailed rules”.

Bailey’s speech, in fact, recognises the increasing interactions between the FCA’s work and broader public and social policy, noting that “there are inevitably boundary issues to be dealt with, for instance with social policy in areas such as benefits, pension, social welfare and housing policy.” Where this is the case, he says the FCA will work closely with the government on its “broader public policy priorities” (and, indeed, the Bank of England on its policy objectives), while maintaining its operational independence.

(ii) Demographic change, where the FCA wants to “deepen” its understanding of the “intergenerational question for financial services”, in order to understand better the financial needs and challenges faced by different generations of consumers, as well as sharpen the clarity of its expectations on the treatment of vulnerable consumers. In some respects this is a new characterisation of a priority in last year’s plan covering “Long-term savings, pensions and intergenerational differences”. This year, however, there is less emphasis on particular products like pensions, and a greater focus on the FCA wanting to understand the differing needs between generational cohorts of financial consumers and how the FS sector can respond to these. The FCA plans a DP and a “major conference” on this issue.

Areas of note in the Business Plan

  • Andrew Bailey’s introduction puts a renewed emphasises on firm's culture, emphasising that the FCA will promote “healthy cultures where the driving purpose leads people to take personal responsibility for consumer and market outcomes, to do the right thing competently and to speak up and to listen to others”.

  • He also highlights the issue of price discrimination and promises that the FCA will “tackle the fact that longstanding customers pay much higher prices than new customers”.

  • The priorities on “EU withdrawal and international engagement”, “Firms’ culture and governance”, “Financial crime and anti-money laundering” and “Fair treatment of existing customers” remain unchanged from last year’s Business Plan. However, there are some minor changes in emphasis with the treatment of existing customers now becoming “fair” treatment, and EU withdrawal being broadened to include “international engagement”, reflecting the FCA’s desire to continue influencing international regulation post Brexit.

  • Importantly, culture and governance, financial crime and AML, and the treatment of existing customers have now been priorities across three Business Plans in a row, reflecting their enduring importance to the FCA.

  • Last year’s “Data security, resilience and outsourcing” priority is largely carried over in this years “Operational resilience” theme, while “Innovation, big data, technology and competition” becomes “Innovation, data and data ethics”. Notably, the FCA will be increasingly focused on how firms use both consumer and regulatory data and the ethics of these uses.

  • Last year’s “high cost credit” priority is dropped, reflecting the considerable work the FCA has undertaken in this area, including on overdrafts and rent-to-own products.

Annex 1: Cross-sector priorities

The table below outlines the FCA Business Plan’s cross-sector priorities for 2019/20, and the key activities and initiatives associated with each of them.

Cross sector priority

Key activity/initiatives

EU Withdrawal and international engagement


The FCA describes EU withdrawal as its “immediate priority”, going on to say that it expects Brexit to place “considerable demands” on it.

The FCA will:
· Provide the government with technical advice and support on withdrawal issues.

· Strengthen its engagement with international regulators.

· Engage with the wider financial services sector to assess the effects of Brexit.

Firms’ culture and governance

The FCA will:

· Work with firms and the academic community to support cultural transformation in the financial services industry, and will hold a number of roundtables, cultural sprints and its second annual transforming culture conference to support this.

· Look at the case for creating more “purposeful” cultures, continue to evaluate firms’ remuneration and recognition practices.

· Extend the Senior Managers and Certification Regime to all firms.

· Establish a Directory which will act as a public register of individuals in key roles who will not be captured by the Senior Managers and Certification Regime.

Operational Resilience

The FCA will:

· Follow up on its earlier discussion paper by publishing a joint consultation paper on Operational Resilience with the Bank of England. [Q3 2019/20]

· Look at third-party service providers, with a focus on understanding the current outsourcing and third party environment and which sectors and services are most dependent on them.

· Having found IT-driven change programmes to be the single largest cause of operational disruptions, review a number of firms to understand their approaches to change management and the causes of these problems.

· Roll out CBEST testing to a larger number of priority firms.

· Carry out a multi-firm review to understand firms’ weaknesses to cyber-attacks. [Q4 2019/20]

· Develop further ways of getting cyber resilience information to smaller firms.

· Continue to respond to major incidents alongside the Bank of England, Treasury, PRA and National Cyber Security Centre.

Financial crime (fraud & scams) and anti-money laundering (AML)

The FCA will:

· Focus on improving its AML capabilities.

· Collaborate closely with law enforcement partners and other agencies to tackle financial crime.

· Consider extending its financial crime data return to a larger number of firms.

· Support the use of innovative AML-related RegTech.

· Work closely with Professional Body Supervisors to address weaknesses at firms.

· Focus on tackling scams.

Fair treatment of existing customers

The FCA will:

· Publish the interim report of the general insurance pricing practices market study. [Summer 2019]

· Publish a feedback statement on the FCA’s fair pricing in financial services discussion paper. [Q2 2019/20]

· Consider the case for a basic savings rate when it publishes responses to the cash savings discussion paper. [Q2 2019/20]

· Carry on the work of its mortgage market study by undertaking further analysis of those customers who do not switch mortgages.

Innovation, data and data ethics

The FCA will:

· Review the Open Banking rules which require banks to share their data.

· Publish a call for input on Open Finance later in 2019.

· Launch a credit information market study.

· Publish a discussion paper on whether the FCA’s treating customers fairly principles adequately cover data ethics in financial services. [Q4 2019/20]

· Publish a feedback statement on its review of cryptoassets as well as finalised perimeter guidance.

· Examine how to express its data requirements for firms in a machine readable and executable form.

· Host an international Tech Sprint on AML and Financial Crime RegTech solutions.

· Run workshops to identify technological solutions which could help support vulnerable consumers.

· Publish a call for input on data use and access to data in wholesale markets. [Q2 2019/20]

Demographic change

The FCA will:

· Publish a discussion paper on intergenerational issues, looking at the differing needs of different generational cohorts across the financial services sectors. [Q1 2019/20]

· Host a conference on intergenerational issues, following up on its discussion paper.

· Launch the second wave of its Financial Lives survey to continue tracking how retail consumers use and interact with financial services.

· Publish guidance for firms on the identification and treatment of vulnerable consumers later in 2019.

The future of regulation

The FCA will:

· Publish a feedback statement on a Duty of Care in the spring of 2019, following on from its earlier discussion paper.

· Look at how its Handbook can be made machine readable and executable in future.

· Look at the regulatory costs it imposes upon the smallest authorised firms, which will inform its Handbook review.

· Publish an annual statement on its view of perimeter issues, reflecting the fact that consumer harm often takes place where there is confusion about the boundaries of FCA regulation.

· Publish a discussion paper on reviewing the FCA’s Principles. [Q4 2019/20]

Annex 2: Sector priorities

The Business Plan also notes a number of key activities related to each of the FCA’s Sectors.


Key activity/initiatives



The FCA says that its operational resilience cross-sector priority is particularly relevant to this sector.

The FCA will:

· Supervise the implementation of the new requirements on fund governance and investor disclosures introduced as part of its Asset Management Market Study, once they come into force at the end of September 2019.

· Take forward remedies related to the CMA’s inquiry into investment consultancies and fiduciary management services.

· Implement the Revised Shareholder Rights Directive (SRD II) and evaluate responses from its Discussion Paper on stewardship.

· Publish a consultation paper on introducing a new prudential regime for MiFID investment firms. [Q3 2019/20]

· Publish a policy statement with final rules and guidance on open-ended funds with illiquid assets. [Q2 2019/20]

· Review asset managers’ compliance with MIFID II’s product governance requirements.

Retail lending

The FCA will:

· Implement the interventions on overdrafts, rent-to-own and other markets covered in its high-cost credit review.

· Undertake work to identify business models that drive unaffordable lending by relying on consumers who cannot afford to repay.

· Implement the remedies from its mortgages market study.

· Publish a policy statement on overdraft pricing. [June 2019]

· Publish a policy statement on “buy now pay later” offers. [June 2019]

· Present its findings on whether there is need for more online information about credit options.

· Launch a credit information market study. [Summer 2019]

· Take on the regulation of claims management companies (CMCs). [1st April 2019]

Pensions and retirement income

The FCA will:

· Publish a policy statement setting out the remaining remedies from its retirement outcomes review. [July 2019]

· Publish feedback on the themes from the responses and evidence from its non-workplace pensions discussion paper.

· Consult on proposals related to contingent charging for pensions transfer advice. [Summer 2019]

· Work with The Pensions Regulator to review how effectively the information from pension schemes and providers combine with guidance and advice services.

· Publish a policy statement setting out new rules for Independent Governance Committees. [Q3 2019/20]

· Continue to work with the government and industry on the pensions dashboard.

Retail investments

The FCA will:

· Carry out a second assessing suitability review, with the findings to be published in 2020.

· Begin a post-implementation review of RDR and FAMR, with the findings to be published in 2020.

· Follow up on its investment platforms market study by assessing industry progress in improving the speed of transfers and customer communications during the transfer process.

· Publish a policy statement on loan-based crowdfunding platforms. [Q2 2019/20]

· Announce the timing of final rules restricting the sale, marketing and distribution of contracts for difference (CFDs). [April 2019]

Retail banking

The FCA will:

· Implement its payments sector strategy

· Begin follow up work from its strategic review of retail bank business models. This will include work to: analyse the value chain in new payments business models, monitor changes to the market, and review the SME banking market.

· Monitor new PSD2-related rules intended to crack down on different forms of fraud by requiring firms to start collecting and reporting detailed fraud statistics.

· Work to ensure open banking services are introduced securely, monitoring the number and nature of new services on the market and the numbers of customers using them.

· Complete the payment protection insurance (PPI) redress scheme. [29 August 2019]

General insurance and protection

The FCA will:

· Follow up on the work of its general insurance distribution chains thematic review.

· Subject to feedback, publish a policy statement on extending its GI value measures reporting requirements. [Q3 2019/20]

· Monitor the level of claims inflation for motor insurance (in relation to the Civil Liability Act).

· Consult on a requirement for firms to direct consumers towards providers who offer travel insurance for consumers with certain medical conditions, if the firm won’t insure the consumer themselves.

· Evaluate the rules it introduced in 2017 to encourage consumers to shop around when renewing their insurance.

Wholesale financial markets

The FCA will:

· Scrutinise firms’ compliance with the Market Abuse Regulation (MAR).

· Help oversee the transition away from LIBOR by supporting the market-led Working Group on Sterling Risk-Free Reference Rates, and by widening its supervision of firms’ transition away from LIBOR.

· Carry out further work to assess firms’ compliance with MIFID II, with a focus on conflicts of interest.

· Issue a call for input on access and use of wholesale markets financial data. [Q2 2019/20]

· Implement the EU Prospectus Directive. [July 2019]

· Work to ensure the EU Securitisation Regulation is well implemented.

· Implement the EU Regulated Covered Bond Regulation in the UK.

· Work with the Financial Reporting Council to ensure the changes to annual corporate reports to mandate reporting in an electronic format (known as the European Single Electronic Format) are implemented.

· Ensure it is ready to take over the regulation of UK trade repositories (TRs), credit rating agencies (CRAs) and Securitisation Repositories (SRs) once the UK has left the EU.

· Consult on changes to the Listing Rules to facilitate Standard, rather than Premium, Listing of ETFs and considering how to improve retail investors’ access to debt markets.


The FCA also recently published a Dear CEO letter to brokers operating in wholesale financial market. It said its supervisory programme of work would focus on; compensation and incentives, culture and governance, capacity and conflicts of interest, market abuse and financial crime controls, technology, and EU withdrawal.

Andrew Bulley

Andrew Bulley - Partner, Centre for Regulatory Strategy

Andrew Bulley joined Deloitte in October 2016 from the Bank of England, where he was, most recently, the Director of Life Insurance Supervision. Between 2014 and 2016 he was a UK voting member of the Board of Supervisors of the European Insurance and Occupational Pensions Authority (“EIOPA”). In a career with the Bank of England and Financial Services Authority stretching over 27 years, Andrew has held senior roles in the supervision of life and general insurers, the London wholesale insurance underwriting and broking markets, retail and investment banks, asset managers, and IFAs.

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David Strachan – Partner, Head of EMEA Centre for Regulatory Strategy

David is Head of Deloitte’s EMEA Centre for Regulatory Strategy. He focuses on the impact of regulatory changes - both individual and in aggregate - on the strategies and business/ operating models of financial services firms. David joined Deloitte after 12 years at the FSA, where in his last role, Director of Financial Stability, he worked on the division of the FSA into the PRA and the FCA.

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Henry Jupe, Associate Director, EMEA Centre for Regulatory Strategy, Risk Advisory

Henry specialises in regulation in the insurance sector. He has advised many insurers across the life, non-life and health sectors on the impact and implementation of regulatory change, and has particular expertise in capital, solvency and regulatory reporting. Henry has worked in Europe and the United States, and is a Chartered Accountant.

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Orla Hurst - Senior Manager, Centre for Regulatory Strategy

Orla is a Senior Manager in Deloitte’s Centre for Regulatory Strategy where she focuses on Conduct Regulation. She has extensive experience of working with financial services firms to help them understand the strategic and operational implications of changes to conduct regulation. She joined Deloitte in June 2017.

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Felix Bungay, Manager, Centre for Regulatory Strategy

Felix is a Manager within the EMEA Centre for Regulatory Strategy, where he focuses on conduct regulation across a range of financial services sectors. Prior to joining Deloitte, Felix worked at the FCA where he helped produce a wide range of the organisation's House and Sector Views, including those on Retail Banking and Lending, Retail Investments and Wholesale Capital Markets.

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Quentin  Mosseray, Senior Associate, Audit and Risk Advisory

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