Recommendation 13

The lack of a cost benefit analysis has contributed to industry concern that the full impact of the proposals on firms and markets was not being suitably considered. Although there is no obligation for the FCA to provide cost benefit analysis on these proposals, the significance of the changes warrants one. Assessment of these proposals cannot simply be a case of ‘articulating the benefits’—it is incumbent on the FCA to demonstrate that a robust and detailed analysis of the costs form part of its evidence base for these proposals.