FSA Annual Report 2006/07 - Better Regulation Ltd

FSA Annual Report 2006/07 - Better Regulation Ltd FSA Annual Report 2006/07 - Better Regulation Ltd

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Section three – Improving our business capability and effectiveness FSA Annual Report 2006/07 37 Improving our business capability and effectiveness Introduction Improving our business capability and effectiveness encompasses the investment we make in our people and information systems and in improving our processes to make it easier for firms, consumers and other stakeholders to do business with us. During the year we have made improvements in areas that directly affect our stakeholders, such as core regulatory transactions, integrated regulatory reporting and contact centres. Overall, the standards we use to measure our performance show that the level of service we offer our stakeholders continues to improve. 2006 was also the first full year of using our new enforcement executive settlement procedures, which have enabled us to achieve more prompt redress and remedial action. As outlined elsewhere in this report, we are making progress towards principles-based regulation. To help us measure and report on our effectiveness in delivering regulatory outcomes against our strategic aims we have developed an outcomes performance report (OPR). In April 2007 we published an overview of the OPR and further detail will follow later this year. We have also carried out work to assess the costs and benefits of regulation to help us strike the right balance between discharging our statutory duties and avoiding unjustified costs. Costs of regulation In 2005, together with the Practitioner Panel, we commissioned Deloitte to carry out a study of the costs that firms incur in complying with our rules. The study focused on three sectors (institutional fund management, corporate finance, and retail investment and pensions advice) and estimated, rule by rule, the costs which firms considered they would not incur other than to comply with our requirements (‘incremental costs’). The Deloitte report was published in June 2006. The study confirmed that much of what regulation requires is good business practice. Most of the rules identified as imposing the highest incremental costs were in the retail investment and pensions advice sector and related to point-of-sale disclosure. No individual rules imposed costs of more than minimal significance in the two wholesale sectors, supporting the findings of other studies that regulatory costs in the UK are not generally seen as putting the UK’s wholesale markets at a competitive disadvantage. Alongside the Deloitte report, we published a progress report on our Better Regulation Action Plan. This included our plans to use the results of the Deloitte study to assess the benefits of the regulatory requirements that generate the highest incremental costs (and that, for example, are not required to remain in place as part of the implementation of a directive). Some initiatives were already under way, such as the simplification of our conduct of business rules (see Section two). Others we started work on during the year, including studies of the benefits associated with three of the highest incremental cost rules identified by the Deloitte study: suitability letters; reduction in yield; and the Menu and initial disclosure document. People strategy We continue to attract high quality people through our graduate scheme and experienced hire programme. In September 2006 56 graduates started our graduate scheme and for the first time we entered The Times Top 100 Graduate Employers list. Of the 43 undergraduates who joined our summer internship scheme in 2006, 26 will return on our graduate programme. We have also had continued success in recruiting experienced people, with 307 joining us during the year. Annual turnover for the financial year remains relatively low compared with the financial services sector, at 11%.

38 Section three – Improving our business capability and effectiveness FSA Annual Report 2006/07 We continue to take a total remuneration approach to reward, taking into account people’s salary, bonus and pension. We targeted median market pay through a series of ‘job families’, which resulted in a 4.6% increase in salary costs. This is in line with trends in the highly competitive employment markets and, in particular, reflects pressure in the risk and compliance markets. We have piloted and plan to roll out additional awards to recognise innovative performance that reduces costs and improves the efficient and economic use of our resources. During the year we increased our spending on training, allocating an additional £1 million to providing a five-day residential training course on ARROW II for all front-line supervision staff (800 in total). The course focused on developing technical risk-assessment skills as well as softer skills such as feedback, interviewing and relationship management. Feedback from firms following subsequent supervision visits suggests this training has delivered real improvements in the way our people assess and discuss risk with firms. We also delivered a programme of sector-based training on financial crime to over 400 staff. Our work on improving the performance of our people continues. We have developed a more robust performance management framework and focused on developing the leadership capabilities of our senior management team. Improving our technical infrastructure This year we have made considerable progress in upgrading our information systems and technology. These improvements are necessary if we are to improve our productivity, deliver principles-based regulation and achieve our target of an industry standard IT function by September 2007 and best in class by September 2008. We have recently signed contracts to outsource our IT infrastructure to Fujitsu and our application management services to Xansa. This will enable us to be more flexible in response to changing business needs and will improve our overall IT capability and effectiveness. In addition, in 2006 we entered into strategic alliances with three IT development partners (Capgemini, Tata Consultancy Services and Xansa). We are working with them Integrated Regulatory Reporting (IRR) on several major programmes, including a long-term strategic reporting platform for Integrated Regulatory Reporting and delivering improvements to our electronic application and notification forms. During the year we developed a knowledge management strategy for the efficient and effective use of the information and knowledge we hold throughout the organisation. We have started work on designing a common system for holding data and developing a comprehensive data search tool. We are also improving our records management procedures and have held compulsory training on this for all our people. Improvements in this area will also benefit firms, particularly in a more principlesbased environment when our people will need full access to information to give consistent and timely guidance. We took industry views into account before finalising our new reporting arrangements, which we published in December 2006 and January 2007. Our new arrangements will: • ensure that reporting is a risk-based and proportionate tool for monitoring and mitigating risks to our objectives, taking into account the mix of regulated business a firm undertakes; • align reporting, as far as possible, with the information that firms’ management use to run their businesses; • take into account the impact of prudential changes arising from the CRD and MiFID (see Section one); and • introduce reporting requirements for operators of personal pension schemes and Home Reversion/Home Finance activity, both of which come under our regulatory scope in 2007. We anticipate that our new requirements will reduce the volume of data reported by most firms, with increases for investment management firms as shown in Table 3.1.

Section three – Improving our business capability and effectiveness<br />

<strong>FSA</strong> <strong>Annual</strong> <strong>Report</strong> <strong>2006</strong>/<strong>07</strong><br />

37<br />

Improving our business<br />

capability and effectiveness<br />

Introduction<br />

Improving our business capability<br />

and effectiveness encompasses the<br />

investment we make in our people<br />

and information systems and in<br />

improving our processes to make it<br />

easier for firms, consumers and<br />

other stakeholders to do business<br />

with us. During the year we have<br />

made improvements in areas that<br />

directly affect our stakeholders, such<br />

as core regulatory transactions,<br />

integrated regulatory reporting and<br />

contact centres. Overall, the<br />

standards we use to measure our<br />

performance show that the level of<br />

service we offer our stakeholders<br />

continues to improve. <strong>2006</strong> was also<br />

the first full year of using our new<br />

enforcement executive settlement<br />

procedures, which have enabled us<br />

to achieve more prompt redress and<br />

remedial action.<br />

As outlined elsewhere in this report,<br />

we are making progress towards<br />

principles-based regulation. To help<br />

us measure and report on our<br />

effectiveness in delivering regulatory<br />

outcomes against our strategic aims<br />

we have developed an outcomes<br />

performance report (OPR). In April<br />

20<strong>07</strong> we published an overview of<br />

the OPR and further detail will<br />

follow later this year. We have also<br />

carried out work to assess the costs<br />

and benefits of regulation to help us<br />

strike the right balance between<br />

discharging our statutory duties and<br />

avoiding unjustified costs.<br />

Costs of regulation<br />

In 2005, together with the<br />

Practitioner Panel, we commissioned<br />

Deloitte to carry out a study of the<br />

costs that firms incur in complying<br />

with our rules. The study focused on<br />

three sectors (institutional fund<br />

management, corporate finance, and<br />

retail investment and pensions<br />

advice) and estimated, rule by rule,<br />

the costs which firms considered<br />

they would not incur other than to<br />

comply with our requirements<br />

(‘incremental costs’).<br />

The Deloitte report was published<br />

in June <strong>2006</strong>. The study confirmed<br />

that much of what regulation<br />

requires is good business practice.<br />

Most of the rules identified as<br />

imposing the highest incremental<br />

costs were in the retail investment<br />

and pensions advice sector and<br />

related to point-of-sale disclosure.<br />

No individual rules imposed costs<br />

of more than minimal significance<br />

in the two wholesale sectors,<br />

supporting the findings of other<br />

studies that regulatory costs in the<br />

UK are not generally seen as putting<br />

the UK’s wholesale markets at a<br />

competitive disadvantage.<br />

Alongside the Deloitte report, we<br />

published a progress report on our<br />

<strong>Better</strong> <strong>Regulation</strong> Action Plan. This<br />

included our plans to use the results<br />

of the Deloitte study to assess the<br />

benefits of the regulatory<br />

requirements that generate the<br />

highest incremental costs (and that,<br />

for example, are not required to<br />

remain in place as part of the<br />

implementation of a directive).<br />

Some initiatives were already under<br />

way, such as the simplification of<br />

our conduct of business rules (see<br />

Section two). Others we started<br />

work on during the year, including<br />

studies of the benefits associated<br />

with three of the highest<br />

incremental cost rules identified by<br />

the Deloitte study: suitability letters;<br />

reduction in yield; and the Menu<br />

and initial disclosure document.<br />

People strategy<br />

We continue to attract high quality<br />

people through our graduate scheme<br />

and experienced hire programme. In<br />

September <strong>2006</strong> 56 graduates<br />

started our graduate scheme and for<br />

the first time we entered The Times<br />

Top 100 Graduate Employers list.<br />

Of the 43 undergraduates who<br />

joined our summer internship<br />

scheme in <strong>2006</strong>, 26 will return on<br />

our graduate programme. We have<br />

also had continued success in<br />

recruiting experienced people, with<br />

3<strong>07</strong> joining us during the year.<br />

<strong>Annual</strong> turnover for the financial<br />

year remains relatively low<br />

compared with the financial services<br />

sector, at 11%.

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