Recommendation 181

We also heard that the Consumer Duty had required some firms to undertake unnecessary compliance activity. Hani Kablawi told us: “We knew from the get-go that we do not have volume in that space. It is a retail activity, and we are not a retail bank, and yet a lot of work had to be done to put in place the structures, the processes and the systems to enable us to support that activity should any volume come our way in the future. That is an example of where regulations can be better scoped and more specific to business models.” 279