Recommendation 139

An example of the burdens that firms can incur responding to consumer focussed regulation is the need for firms to demonstrate that their wholesale activities are outside of the scope of consumer regulation. Cuan Coulter told us that: “… our business is almost entirely an institutional business … we, as an organisation, had to spend a significant amount of time—in the order of several thousand man-hours—developing an articulation of why the consumer duty framework did not apply to our business model, notwithstanding the fact that we do not have any retail presence.” 210