Recommendation 196

Failing to address the issues we have identified in this Chapter risks deepening the perception that there is a regulatory ‘risk premium’ or penalty that reduces the attractiveness of investing in the UK and poses a serious constraint on the advancement of the aims of the secondary objective. 39 Written evidence from OakNorth Bank ( SCG0020 ) 40 Supplementary written evidence from Aberdeen Group ( SCG0068 ) 41 The Rt Hon Rachel Reeves MP, Chancellor of the Exchequer, Mansion House 2024 Speech, 14 November 2024: https://www.gov.uk/government/ speeches/mansion-house-2024-speech [accessed 10 May 2025] 42 Q 330 (Andy Briggs) 43 Q 155 (Charles Randell) 44 Q 298 (Sam Woods). See also Q 240 (Bim Afolami). 45 Q 243 (Andrew Griffith MP) 46 Written evidence from the Lloyd’s Market Association ( SCG0031 ) 47 Q 130 (Nigel Terrington) 48 Financial Services and Markets Act 2000, section 165 49 Written evidence from Nationwide Building Society ( SCG0019 ) 50 Written evidence from Santander UK ( SCG0046 ) 51 See Appendix 4. 52 Ibid. 53 Q 47 (Caroline Wagstaff) 54 Q 271 (Hannah Gurga) 55 Written evidence from Santander UK ( SCG0046 ) 56 Q 254 (Debbie Crosbie) 57 Q 203 (Chris Cummings) 58 Q 328 (Andy Briggs) 59 Q 270 (Hannah Gurga) 60 FCA, Consultation Paper CP23/20: Diversity and inclusion in the financial sector—working together to drive change (25 September 2023): https:// www.fca.org.uk/publication/consultation/cp23-20.pdf [accessed 10 May 2025] 61 PRA, Consultation Paper CP18/23: Diversity and inclusion in PRA-regulated firms ( 25 September 2023 ): https://www.bankofengland .co.uk/-/media/boe/files/prudential-regulation/consultation-paper/2023 /september/cp1823-diversity-and-inclusion-in-pra-regulated-firms.pdf [accessed 10 May 2025] 62 Q 12 (Miles Celic) 63 Q 187 (Sir Howard Davies) 64 Q 279 (Hani Kablawi) 65 Bank of England, ‘Statement on CP18/23—diversity and inclusion in PRA-regulated firms’ (12 March 2025): https://www.bankofengland .co.uk/news/2025/march/statement-on-cp18-23-diversity-and -inclusion-in-pra-regulated-firms [accessed 10 May 2025]; FCA, ‘Update on the FCA’s enforcement transparency proposals’ (12 March 2025): https://www.fca.org.uk/news/statements/update-fca -enforcement-transparency-proposals [accessed 10 May 2025] 66 Q 244 (Andrew Griffith MP) 67 Ibid. 68 Financial Services and Markets Act 2023, section 27 69 Q 342 (Nikhil Rathi) 70 Q 341 (Nikhil Rathi) 71 Q 342 (Nikhil Rathi) 72 Q 292 (Sam Woods) 73 Q 12 (Miles Celic) 74 Q 254 (Julie-Ann Haines) 75 Written evidence from Nationwide Building Society ( SCG0019 ) 76 Supplementary written evidence from the Investment Association ( SCG0058 ) 77 Ibid. 78 See Appendix 5. 79 Written evidence from Nationwide Building Society ( SCG0019 ) 80 Supplementary written evidence from the Investment Association ( SCG0058 ) 81 Written evidence from the Association of British Insurers ( SCG0033 ) 82 Written evidence from the British Private Equity & Venture Capital Association ( SCG0053 ) 83 Q 34 (Christopher J. Lay) 84 Supplementary written evidence from the Investment Association ( SCG0058 ) 85 Written evidence from the London Market Group ( SCG0075 ) 86 Q 102 (Professor Kern Alexander) 87 Supplementary written evidence from the Investment Association ( SCG0058 ) 88 HM Treasury, ‘New approach to ensure regulators and regulation support growth’ (17 March 2025): http://www.gov.uk/government/publications/a-new- approach-to-ensure-regulators-and-regulation-support-growth/new-approach- to-ensure-regulators-and-regulation-support-growth-html [accessed 10 May 2025] 89 Supplementary written evidence from the Investment Association ( SCG0058 ); Written evidence from ClearBank ( SCG0006 ) 90 FCA, Statement of Policy on Cost Benefit Analyses (29 July 2024) p 6: https://www.fca.org.uk/publication/corporate/statement-policy-cba. pdf [accessed 10 May 2025] 91 The Consumer Duty is a cross-cutting regulatory principle that requires firms to ensure products and services provide good outcomes for consumers. See paragraphs 176–192. 92 Written evidence from the Personal Investment Management & Financial Advice Association ( SCG0025 ) 93 Supplementary written evidence from the Investment Association ( SCG0058 ) 94 Q 201 (Chris Cummings) 95 The Cost Benefit Analysis (CBA) Panel is a statutory panel established by FSMA 2023 within the FCA that reviews and advises on the regulator’s use of cost benefit analysis. See FCA, ‘Cost Benefit Analysis Panel’: https://www.fca.org.uk/panels/cost- benefit-analysis-panel [accessed 10 May 2025]. 96 FCA Cost Benefit Analysis Panel, Interim Annual Report: May-September 2024 (10 January 2025) p 20: https://www.fca.org.uk/panels/ cost-benefit-analysis-panel/publication/cba-panel-annual-report-2024. pdf [accessed 10 May 2025] 97 Written evidence from TheCityUK ( SCG0016 ) 98 FCA Cost Benefit Analysis Panel, Interim Annual Report: May-September 2024 (10 January 2025) p 17: https://www. fca.org.uk/panels/cost-benefit-analysis-panel/publication/cba- panel-annual-report-2024.pdf [accessed 10 May 2025] 99 Ibid. 100 Ibid. , p 20 101 Financial Services Regulation Committee, Naming and shaming: how not to regulate (1st Report, Session 2024–25, HL Paper 76) paras 98–108 102 Written evidence from Lloyd’s of London ( SCG0022 ) 103 Written evidence from the Association of British Insurers ( SCG0033 ) 104 Supplementary written evidence from the Investment Association ( SCG0058 ) 105 Written evidence from the Lloyd’s Market Association ( SCG0031 ) 106 Financial Services and Markets Act 2000, sections 1B , 1C , 1D , 1E , 2B , and 2C 107 Regulators that interact with financial services firms include the FCA, PRA, PSR, Financial Reporting Council (FRC), Competition and Markets Authority (CMA), Lending Standards Board (LSB), Information Commissioner’s Office (ICO), and The Pensions Regulator (TPR). See supplementary written evidence from Nationwide Building Society ( SCG0056 ). 108 Supplementary written evidence from Nationwide Building Society ( SCG0056 ) 109 Ibid. 110 Q 202 (Chris Cummings) 111 Q 201 (Chris Cummings) 112 The Senior Managers and Certification Regime (SM&CR) comprises several, mutually reinforcing elements, centred on the Senior Managers Regime, the Certification Regime, and the Conduct Rules. The Senior Managers Regime requires the regulators to authorise individuals to hold certain senior manager functions. The Certification Regime requires the regulators to define certified functions, for which firms must certify staff on appointment and at least every 12 months to ensure that they meet the fit and proper test. See PRA, ‘Discussion Paper DP1/23: Review of the Senior Managers and Certification Regime (SM&CR)’ (30 March 2023): https://www.bankofengland.co.uk/ prudential-regulation/publication/2023/march/review-of-the-senior-managers- and-certification-regime [accessed 11 May 2025]. 113 Written evidence from Lord Blackwell ( SCG0007 ) 114 Written evidence from the Lloyd’s Market Association ( SCG0031 ) 115 HM Treasury, Press Release: Chancellor fires up financial services sector to drive growth on 14 November 2024: https://www.gov.uk/government/news/chancellor-fires- up-financial-services-sector-to-drive-growth [accessed 11 May 2025] 116 Operational resilience regulations ensure that firms can withstand operational shocks such as service outages, cyber-attacks, and the failure of outsourced business functions with the minimum disruption to their commercial activities. See FCA, Policy Statement PS21/3: Building operational resilience—Feedback to CP19/32 and final rules (29 March 2021) p 3: https://www.fca.org.uk/publication/policy/ps21-3- operational-resilience.pdf [accessed 11 May 2025]. 117 Q 282 (Hani Kablawi) 118 Ibid. 119 Written evidence from Principality Building Society ( SCG0060 ) 120 Ibid. 121 Written evidence from Aberdeen Group ( SCG0008 ) 122 Q 353 (Emma Reynolds MP) 123 Written evidence from Phoenix Group ( SCG0042 ) 124 Q 119 (David Postings) 125 The Lending Standards Board (LSB) is the self-regulatory body for the banking and lending industry which sets and oversees a range of consumer standards and codes. See Thomson Reuters Practical Law, ‘Glossary: Lending Standards Board (LSB)’: https://uk.practicallaw. thomsonreuters.com/2-500-6741?transitionType=Default&contextData=(sc.Default)&firstPage=true [accessed 11 May 2025]. 126 Written evidence from Nationwide Building Society ( SCG0019 ) 127 The Joint Regulatory Oversight Committee (JROC) was formed in 2022 and comprised the regulators with responsibility for Open Banking, including the FCA, PSR, and CMA, along with HM Treasury. See FCA and PSR, Joint Regulatory Oversight Committee: Terms of reference (24 June 2022) p 1: https://www. fca.org.uk/publication/corporate/joint-regulatory-oversight-committee-tor. pdf [accessed 11 May 2025]. 128 Open Banking is a system that allows customers to share financial information securely from institutions such as banks and building societies with trusted third parties to facilitate a range of services including tailored financial services and faster account-to-account payments. See HM Treasury, National Payments Vision (14 November 2024) pp 28–29: https://assets. publishing.service.gov.uk/media/6736385fb613efc3f182317a/National_Payments_Vision..pdf [accessed 11 May 2025]. 129 Written evidence from Nationwide Building Society ( SCG0019 ) 130 Written evidence from TrueLayer ( SCG0070 ) 131 Variable Recurring Payments would allow customers to authorise repeated payments at flexible intervals and of varying amounts, facilitating more flexible and efficient billing. See PSR, Expanding variable recurring payments: Response to the call for views (CP23/12) (15 August 2024) p 5: https://www.psr.org.uk/media/tovd1ygd/rp24-1-expanding-vrp -consultation-response-aug-2024-v3.pdf [accessed 11 May 2025]. 132 Written evidence from UK Finance ( SCG0039 ) 133 HM Treasury, National Payments Vision (14 November 2024) p 29: https://assets. publishing.service.gov.uk/media/6736385fb613efc3f182317a/National_Payments_Vision..pdf [accessed 11 May 2025] 134 Ibid. , p 31 135 Q 267 (Debbie Crosbie) 136 Financial Services and Markets Act 2000, sections 19 , 20 , and 23 137 Ibid. , sections 55L and 55M 138 Ibid. , section 61 139 Q 201 (Chris Cummings) 140 Q 34 (Caroline Wagstaff) 141 Ibid. 142 FCA, Secondary International Competitiveness and Growth Objective report 2023/24 (29 July 2024) p 12: https://www.fca.org.uk/publication/corporate /sicgo-report-2023–24.pdf [accessed 10 May 2025] 143 Written evidence from the British Insurance Brokers’ Association ( SCG0011 ) 144 Written evidence from the Association of Foreign Banks ( SCG0026 ) 145 Ibid. 146 Monetary Authority of Singapore, Guidelines on Individual Accountability and Conduct (10 September 2020): https://www.mas.gov.sg/-/media /mas/mpi/guidelines/guidelines-on-individual-accountability-and-conduct.pdf [accessed 5 June 2025] 147 Written evidence from the City of London Corporation ( SCG0043 ). See also Q 278 (Hani Kablawi). 148 Written evidence from the City of London Corporation ( SCG0043 ) 149 Written evidence from the City of London Corporation ( SCG0043 ) 150 Q 101 (Professor Kern Alexander) 151 Q 13 (Miles Celic) 152 Ibid. 153 HM Treasury, Insurance linked securities: Consultation (1 March 2016) pp 3–4: https://assets.publishing.service.gov.uk/ media/5a808dde40f0b62305b8bd3b/Insurance_linked_securities_consultation.pdf [accessed 11 May 2025] 154 Written evidence from Aon ( SCG0030 ) 155 Q 166 (Janine Hirt) 156 Ibid. 157 Q 78 (Sandra Boss) 158 Written evidence from TheCityUK ( SCG0016 ) 159 Q 194 (Charles McManus) 160 Written evidence from the Digital Currencies Governance Group ( SCG0021 ). The EU Markets in Crypto Assets Regulation (MiCA), which entered into force in June 2023, establishes uniform EU market rules for crypto-assets and related services that are not currently regulated by existing EU financial services legislation. See European Securities and Markets Authority (ESMA), Consultation Paper: Technical Standards specifying certain requirements of the Markets in Crypto Assets Regulation (MiCA) (12 July 2023) p 8: https://www.esma.europa.eu/sites /default/files/2023–07/ESMA74-449133380–425_MiCA_Consultation_Paper_1st_package.pdf [accessed 4 June 2025]. 161 Written evidence from Innovate Finance ( SCG0049 ) 162 Q 211 (Soups Ranjan) 163 Q 211 (Simon Taylor) 164 Q 167 (Janine Hirt); Written evidence from Zurich Insurance ( SCG0023 ); Written evidence from the City of London Corporation ( SCG0043 ) 165 Written evidence from TheCityUK ( SCG0016 ) 166 Ibid. 167 Written evidence from Innovate Finance ( SCG0049 ) 168 Ibid. 169 Q 78 (Sandra Boss) 170 Written evidence from Innovate Finance ( SCG0049 ) 171 Q 212 (Simon Taylor) 172 Q 212 (Soups Ranjan) 173 Q 21 (Chris Hayward) 174 Written evidence from Sir Nicholas Lyons ( SCG0067 ) 175 Q 160 (Charles Randell) 176 Q 26 (Kerstin Mathias) 177 Written evidence from Sir Nicholas Lyons ( SCG0067 ) 178 Letter from Sam Woods, Deputy Governor for Prudential Regulation and Chief Executive Officer of the PRA, to the Rt Hon Sir Keir Starmer MP, Prime Minister, the Rt Hon Rachel Reeves MP, Chancellor of the Exchequer, and the Rt Hon Jonathan Reynolds MP, Secretary of State for Business and Trade (15 January 2025) p 5: https://www.bankofengland.co.uk/-/media/boe/files/ prudential-regulation/letter/2025/pra-response-letter-15-january-2025. pdf [accessed 12 May 2025] 179 Ibid. 180 Q 302 (Sam Woods) 181 Q 341 (Nikhil Rathi) 182 Q 280 (Hani Kablawi) 183 Q 280 (Anna Dunn) 184 Written evidence from Innovate Finance ( SCG0049 ) 185 Ibid. 186 Written evidence from Allica Bank ( SCG0052 ) 187 Supplementary written evidence from Allica Bank ( SCG0076 ) 188 PRA, Supervisory Statement SS31/15: The Internal Capital Adequacy Assessment Process (ICAAP) and the Supervisory Review and Evaluation Process ( SREP) (29 July 2015): https://www.bankofengland.co.uk/-/media /boe/files/prudential-regulation/supervisory-statement/2025/ss3115-february-2025 -update.pdf [accessed 12 May 2025] 189 Supplementary written evidence from Allica Bank ( SCG0076 ) 190 Embedded banking is the integration of financial services, such as banking and payment systems, into non-financial platforms. See Bain Capital and Bain & Company, Embedded Finance: What It Takes to Prosper in the New Value Chain (September 2022) p 5: https://www.bain.com/contentassets /a5ad904e61324de88b62707de879f174/bain_brief_embedded-finance.pdf [accessed 12 May 2025]. 191 Written evidence from ClearBank ( SCG0006 ) 192 Ibid. 193 Q 44 (Christopher J. Lay) 194 Ibid. 195 Written evidence from Lord Blackwell ( SCG0007 ) 196 Written evidence from TheCityUK ( SCG0016 ) 197 Q 214 (Cuan Coulter) 198 Written evidence from Aon ( SCG0030 ) 199 Supplementary written evidence from ClearBank ( SCG0059 ) 200 Q 335 (Ashley Alder) 201 Written evidence from the FCA ( SCG0074 ) 202 Q 309 (Sam Woods) 203 Q 309 (David Bailey) 204 Written evidence from the Alternative Investment Management Association ( SCG0015 ) 205 Q 182 (Sir Howard Davies) 206 Q 244 (Andrew Griffith MP) 207 Q 183 (Sir Howard Davies) 208 Ibid. 209 Written evidence from Aon ( SCG0030 ) 210 Q 214 (Cuan Coulter) 211 FCA, ‘Consumer Duty: Findings from our review of fair value frameworks’ (10 May 2023): https:// www.fca.org.uk/publications/good-and-poor-practice/consumer- duty-findings-our-review-fair-value-frameworks [accessed 12 May 2025] 212 Written evidence from the London Market Group ( SCG0075 ) 213 Q 95 (Professor Kern Alexander) 214 Written evidence from Monzo ( SCG0029 ) 215 PRA, Review of ring-fencing rules (25 January 2024) p 7: https://www.bankofengland.co.uk/-/media/boe/ files/prudential-regulation/publication/2024/review-of-ring-fencing-rules. pdf [accessed 12 May 2025] 216 Q 178 (Sir Howard Davies) 217 Written evidence from the City of London Corporation ( SCG0043 ) 218 Q 191 (Richard Davies) 219 See Appendix 5. 220 Q 191 (Charles McManus) 221 Financial Ombudsman Service, Annual report and accounts for the year ended 31 March 2020 (5 November 2020) p 5: https://www.financial-ombudsman.org. uk/files/287580/Annual-Report-and-Accounts-for-the-year- ended-31-March-2020.pdf [accessed 12 May 2025] 222 Financial Ombudsman Service, Policy statement: Charging claims management companies and other professional representatives (7 February 2025) p 3: https://www. financial-ombudsman.org.uk/files/324553/Charging-professional-representatives-Policy- statement.pdf [accessed 12 May 2025] 223 Financial Ombudsman Service, ‘ How we make decisions ’: https://www.financial-ombudsman.org.uk/ who-we-are/make-decisions [accessed 12 May 2025] 224 Financial Services and Markets Act 2000 , section 228 225 FCA, ‘DISP 3.6: Determination by the Ombudsman’, FCA Handbook : https://www. handbook.fca.org.uk/handbook/DISP/3/6.html [accessed 12 May 2025] 226 The members of the Wider Implications Framework are the FCA, FOS, Financial Services Compensation Scheme (FSCS), The Pensions Regulator (TPR), and the Money and Pensions Service (MaPS). See Wider Implications Framework, Annual Report 2022 (19 April 2023) p 3: https://www.financial-ombudsman.org.uk/files/324217/ Wider-Implications-Framework-Annual-Report-2022_ACC.pdf [accessed 12 May 2025]. 227 Financial Services and Markets Act 2000 , section 415C 228 FCA and Financial Ombudsman Service, Call for Input: Modernising the Redress System (15 November 2024) p 23: https:// www.fca.org.uk/publication/call-for-input/call-for- input-modernising-redress-system.pdf [accessed 12 May 2025] 229 The FOS and FCA have themselves recognised this. They have stated: “There is also a risk that the FCA will ultimately move forward with a regulatory solution which is different to the outcome the Financial Ombudsman may have reached on individual complaints. This is anticipated in FSMA and understood by the courts, but it can suggest inconsistency in the system.” See FCA and Financial Ombudsman Service, Call for Input: Modernising the Redress System (15 November 2024) p 12: https://www. fca.org.uk/publication/call-for-input/call-for-input- modernising-redress-system.pdf [accessed 12 May 2025]. 230 UK Finance and White & Case, Review of statutory dispute-resolution processes in the banking and finance sector (16 February 2021) p 2: https://www.ukfinance.org.uk/system/files/Review%20of% 20statutory%20dispute-resolution%20processes%20in%20the%20banking%20-%20FINAL.pdf [accessed 12 May 2025] 231 Written evidence from the City of London Corporation ( SCG0043 ) 232 Ibid. 233 Q 236 (Bim Afolami) 234 Ibid. 235 Q 326 (Andy Briggs) 236 Financial Ombudsman Service, Press Release: Financial Ombudsman Service to start charging professional representatives to refer cases on 7 February 2025: https://www.financial-ombudsman.org. uk/news/financial-ombudsman-service-start-charging-professional-representatives-refer- cases [accessed 12 May 2025] 237 Ibid. 238 Finance & Leasing Association, ‘FLA response to FCA/FOS Call for Input on Modernising the Redress System’ (31 January 2025): https://fla.org. uk/news/fla-response-to-fca-fos-call-for-input- on-modernising-the-redress-system/ [accessed 12 May 2025] 239 FCA and Financial Ombudsman Service, Call for Input: Modernising the Redress System (15 November 2024) p 6: https://www.fca .org.uk/publication/call-for-input/call-for-input-modernising -redress-system.pdf [accessed 12 May 2025] 240 Q 229 (Stephen Haddrill) 241 Q 228 (Stephen Haddrill) 242 Financial Ombudsman Service, ‘Compensation’: https://www.financial-ombudsman.org.uk/consumers/expect /compensation [accessed 13 May 2025] 243 Financial Ombudsman Service, Press Release: Financial Ombudsman Service to start charging professional representatives to refer cases on 7 February 2025: https://www.financial-ombudsman .org.uk/news/financial-ombudsman-service-start-charging-professional-representatives -refer-cases [accessed 12 May 2025] 244 Ibid. 245 Q 254 (Debbie Crosbie) 246 Written evidence from UK Finance ( SCG0039 ) 247 Written evidence from Nationwide Building Society ( SCG0019 ) 248 Written evidence from St. James’s Place ( SCG0037 ) 249 Written evidence from UK Finance ( SCG0039 ) 250 Written evidence from TheCityUK ( SCG0016 ) 251 Q 236 (Bim Afolami) 252 Q 322 (Andy Briggs) 253 FCA and Financial Ombudsman Service, Call for Input: Modernising the Redress System (15 November 2024): https://www.fca.org.uk/publication/call-for-input/ call-for-input-modernising-redress-system.pdf [accessed 13 May 2025] 254 Ibid. , p 5 255 Financial Ombudsman Service, Press Release: Financial Ombudsman Service and FCA move to modernise redress system on 15 November 2024: https://www.financial-ombudsman.org .uk/news/financial-ombudsman-service-fca-move-modernise-redress-system [accessed 13 May 2025] 256 Ibid. 257 Written evidence from UK Finance ( SCG0039 ), the City of London Corporation ( SCG0043 ), and the Finance & Leasing Association ( SCG0048 ) 258 FCA and Financial Ombudsman Service, Call for Input: Modernising the Redress System (15 November 2024) pp 23–24: https://www.fca.org.uk/publication/call -for-input/call-for-input-modernising-redress-system.pdf [accessed 13 May 2025] 259 Written evidence from UK Finance ( SCG0039 ) 260 Q 332 (Nikhil Rathi) 261 Ibid. 262 Ibid. 263 Q 361 (Emma Reynolds MP) 264 Ibid. 265 HM Treasury, ‘New approach to ensure regulators and regulation support growth’ (17 March 2025): http://www.gov.uk/government/publications/a-new -approach-to-ensure-regulators-and-regulation-support-growth/new-approach -to-ensure-regulators-and-regulation-support-growth-html [accessed 13 May 2025] 266 Ibid. 267 Ibid. 268 The Consumer Duty is Principle 12 of the FCA’s high-level Principles for Businesses. See FCA, ‘PRIN 2.1: The Principles’, FCA Handbook : https://www.handbook.fca.org.uk/handbook/PRIN/2/1.html [accessed 4 June 2025]. 269 FCA, ‘Consumer Duty implementation: good practice and areas for improvement’ (20 February 2024): https://www .fca.org.uk/publications/good-and-poor-practice/consumer-duty -implementation-good-practice-and-areas-improvement [accessed 13 May 2025] 270 FCA, Finalised Guidance FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty (27 July 2022) p 24: https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf [accessed 13 May 2025] 271 FCA, ‘Consumer Duty implementation: good practice and areas for improvement’ (20 February 2024): https://www .fca.org.uk/publications/good-and-poor-practice/consumer-duty -implementation-good-practice-and-areas-improvement [accessed 13 May 2025] 272 Written evidence from Phoenix Group ( SCG0042 ) 273 Written evidence from StepChange Debt Charity ( SCG0071 ) 274 Written evidence from the Investment Association ( SCG0009 ) 275 Q 242 (Andrew Griffith MP) 276 Q 33 (Caroline Wagstaff) 277 Written evidence from State Street ( SCG0055 ) 278 Written evidence from the Lloyd’s Market Association ( SCG0031 ) 279 Q 277 (Hani Kablawi) 280 Written evidence from Monzo ( SCG0029 ) 281 Q 108 (David Postings) 282 Written evidence from UK Finance ( SCG0039 ) 283 Written evidence from the Investment Association ( SCG0009 ) 284 FCA and Financial Ombudsman Service, Call for Input: Modernising the Redress System (15 November 2024) p 6: https://www.fca.org.uk/publication/call-for-input/call- for-input-modernising-redress-system.pdf [accessed 14 May 2025] 285 Q 178 (Sir Howard Davies) 286 Q 349 (Emma Reynolds MP) 287 FCA, Call for Input: Review of FCA requirements following the introduction of the Consumer Duty (29 July 2024) p 5: ttps://www.fca.org.uk/publication/call- for-input/call-for-input-review-retail-conduct-rules.pdf [accessed 14 May 2025] 288 Ibid. , p 6 289 FCA, Feedback Statement FS25/2: Immediate areas for action and further plans for reviewing FCA requirements following introduction of the Consumer Duty (25 March 2025) p 5: https://www.fca.org.uk /publication/feedback/fs25-2.pdf [accessed 14 May 2025] 290 Ibid . , p 4 < Back Next > © Parliamentary copyright 2025 A-Z index Glossary Contact us Freedom of Information Jobs Using this website Copyright Privacy notice Cookie policy Cookie Manager House of Lords - Growing pains: clarity and culture change required - An examination of the secondary international competitiveness and growth objective - Financial Services Regulation Committee Accessibility Email alerts RSS feeds Contact us Home Parliamentary business MPs, Lords & offices About Parliament Get involved Visiting Education House of Commons House of Lords What's on Bills & legislation Committees Publications & records Parliament TV News Topics Growing pains: clarity and culture change required - An examination of the secondary international competitiveness and growth objective Contents Chapter 3: The secondary objective and the wider economy