Regulating the Standards is an important document that describes how the regulatory teams will use In-Depth Assessments (IDAs), Annual Stability Checks and Quarterly Surveys to inform their regulatory judgements, as well detailing the expectations of data returns and notifications. This version replaced that published in December 2016 and outlines some major changes as well as some shifts in emphasis.
To support our clients in quickly identifying where they may need to update their own processes and assurances we have produced a mark-up, highlighting the substantive changes. Click here to read.
In summary, the changes are:
Major:
- Increased attention to be paid to the accuracy of Asset & Liability Registers (2.8)
- Increased focus on the robustness of Stress Testing and the associated mitigations (2.9, 2.10, 2.23 [Table 3.2])
- New section on expectations around Restructures and Disposals, replacing the previous one on Consents (2.43 to 2.49)
- New detail on Registration and De-Registration (6.3 to 6.6)
- New detail in ‘Data and information requirements’ to reflect the new Notification requirements (3.3 to 3.7, Annex A)
Minor:
- Mention that the HCA has a ‘duty to promote economic growth’ (1.7)
- Clarification that HCA does not having a role in resolving individual disputes, but does understand that complaints can be evidence of systemic failure (2.37, Annex B – 5)
- Mention that potential breaches or failures of the Consumer Standards can also result in regulatory action (2.38 to 2.40)
- Confirmation that moves between V1 to V2 are now described as ‘re-grades’ (4.7)
- Mention that concerns regarding the level of service provided in relation to consumer regulation can be raised by going through Stage 2 of the HCA’s complaints procedure. (Annex B – 23)
Campbell Tickell has extensive experience in assisting our clients with all regulation and governance matters, including providing critical friend advice on:
- Strategic, business and financial planning;
- Stress tests;
- Asset and liability registers;
- Risk and assurance;
- Value for money;
- Governance structures;
- Restructures, disposals and mergers;
- Registration and de-registration.
To discuss how we could support you as you take on board these new expectations call Radojka Miljevic, Stephen Bull or Sue Harvey on 020 8830 6777.
