Conclusion 14

Given that the enforcement investigation proposals represent a significant departure from the FCA ’s previous approach, it remains our firm view that proposed changes of this extent necessitate a robust and detailed analysis of the direct costs to the sector. Wider factors in the UK’s growth and competitiveness should form part of this analysis. The need for such an assessment will be underscored if, as happened following the publication of the first consultation, the feedback the FCA receives on its second consultation reiterates the call for a cost benefit analysis—the FCA must be transparent about the views expressed on this issue .