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Welcome to our weekly round-up for UK financial services regulation. Paul Staples summarises the key announcements and developments. Be sure to subscribe to receive our updates in your inbox every week.
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With heightened scrutiny and growing awareness of cyber risk, we lead this week with insights from the Financial Conduct Authority’s (FCA’s) Cyber Coordination Group (CCG) programme. These observations will be of interest to a broad range of stakeholders concerned with operational risk, operational resilience, and third-party risk management.
Elsewhere, with the overhaul of the consumer credit regime in the pipeline, we shine a light on the prevalence of the sector and the FCA’s commitment to its success. And in our third item this week, market efficiency and international convergence are the drivers for the move towards faster settlement times (T+1).
We conclude this week with the FCA’s warning of rising concerns of ‘bad actors’ around motor finance, and updates from the non-bank sector.
Latest cyber insights
The FCA has released insights from the CCG discussions held throughout 2024, drawing on contributions from 139 member firms. These insights focus on three critical areas of cyber resilience:
Reconnection frameworks and third-party management
Threat and vulnerability management and threat-led penetration testing
Artificial intelligence and emerging technologies, including quantum computing
The insights showed progress in cyber resilience, highlighting the value of forums like the Cross Market Operational Resilience Group (CMORG) for co-ordinating with third-party suppliers during outages. Threat-led penetration testing also proved effective at identifying unknown cyber risks, especially when combining external and internal resources.
Despite progress, firms still face ongoing difficulties. Relying on third-party providers with weaker cyber defences can compromise security, and recruiting technical talent for effective threat management is challenging. Firms should test third-party reconnection and update internal AI governance.
Alison Walters, the FCA’s Director of Consumer Finance, has published a blog discussing the future of the consumer credit sector. With credit products becoming embedded in daily life for many (the FCA found in its 2024 Financial Lives Survey that 84% of UK adults had held credit or loans in the past year) Walters highlights that the role of credit in daily life isn't just growing, but evolving.
Notably, it seems that credit is now key to survival for many. Walters states that 21% of UK adults had been overdrawn at some point in the past year, with 5% having persistent credit card debt. Of those with personal loans, 10% (around 1.6 million people) used them for everyday expenses such as food, travel, or rent. It's stressed to firms that compassionate support for those with vulnerabilities is vital going forwards, to ensure that those who do rely on credit have the opportunity to recover from financial hardship.
Walters also highlights the role technology has and will continue to play in transforming the sector. Digital tools are now vital in spotting signs of potential harm and financial difficulty, with the expectation that further innovation by firms will improve accessibility for consumers while ensuring that credit is right for them. This is expected to shape the coming years, with the FCA welcoming firms to work with them in creating the future of the sector.
The FCA has endorsed the UK’s transition to a T+1 securities settlement cycle, set for 11 October 2027. This shift, led by the Accelerated Settlement Taskforce (AST), aims to enhance market efficiency and liquidity. The regulator will use supervision and market monitoring through the transition and encourages firms to engage with the AST and its recommendations. Alignment across European markets around the 11 October 2027 date is a key objective to minimise frictions. Firms are urged to assess AST recommendations now, considering operational changes, third-party agreements, and testing needs.
Key takeaways:
Date set: UK intends to move to T+1 on 11 Oct 2027; EU convergence is desirable
Firms should read the AST recommendations, budget, automate where appropriate, and start testing
The FCA has issued a warning about cold callers impersonating car finance lenders and fraudulently claiming consumers are due compensation, seeking personal details such as names, dates of birth, and bank information. As a result, firms should be mindful to:
ensure robust communication with clients so they understand the official channels and recognise legitimate outreach from the firm
monitor for fraudulent use of the firm’s name and logo and report instances to relevant authorities
educate staff about current scam trends and provide clear procedures for escalating concerns related to impersonation or suspicious contact
review and strengthen client authentication processes to prevent unauthorised access and fraudulent claims
proactively inform clients about active scams and encourage them to verify any unsolicited requests for personal or financial information
maintain vigilant oversight and clear communication to safeguard clients and protect their reputation.
The FCA’s Deputy Chief Executive, Sarah Pritchard, has published reflections on the Financial Stability Board’s (FSB) working group on non-bank leverage, and its recent policy recommendations aimed at addressing risks.
Pritchard states that leverage (borrowing funds to invest) is often used by firms to increase exposure, boost returns or hedge potential losses, but can cause economic instability when poorly managed, concentrated, or hard to spot. UK Government debt markets are highlighted as an example of a market being essential to the stability of the financial system, where poor use of leveraging can be particularly damaging.
With this in mind, the FSB’s recent recommendations seek to identify and address risks to market stability. Stronger monitoring practices, consistent cross-border data sharing and improved disclosure practices between non-banks and leverage providers are put forward as potential options, with the hope that the FCA and its international partners can work together to take these recommendations forward and make them a reality.
The FCA intends to publish its motor finance redress consultation in October. Directors need to understand the actions they can take now to help their firms.
Discover how we supported Essex County Council's implementation of IFRS 16, ensuring compliance, robust lease assessments, and enhanced financial reporting for 2024/25.
