RFCA Governance & Oversight Inadequacy
Inadequate governance and oversight of Reserve Forces and Cadets Associations (RFCAs), requiring significant reform.
Strongest theme matches
Mixed across source types and ranked by classifier confidence plus text match strength.
Committee recommendation
100match
#18 - RFCA governance and oversight require significant reform to support Strategic Defence Review ambitions.
The Department said it is now at an ‘inflection point’ where the governance and oversight of the RFCAs needs to be fit for purpose to support the ambitions in the SDR. In part, the Department intends to achieve this through its desired creation of an NDPB. It explained that other elements involved embedding good governance and oversight and...
Matched on
terms: governance, oversight, rfca
Committee recommendation
98match
#4 - Detail plans to enhance accountability for RFCA performance under current arrangements.
The Department will need to continue to manage around the limitations of its current oversight arrangements for the RFCAs until it has established an NDPB. The Department has improved its oversight of the RFCAs since 2019, implementing around 70% of the Sullivan Review’s recommendations either fully or partially. It now has a single senior responsible owner, the Assistant...
Matched on
terms: governance, oversight, rfca
Committee recommendation
95match
#17 - Balancing national oversight with local volunteer spirit is key challenge for RFCA reform.
The Department said that the challenge is to balance the need for a professional and effective national organisation that can be held to account, with the ability to leverage the membership’s volunteer spirit. It said that there was an ongoing conversation with the RFCAs around 20 Qq 17 and 18 21 Q 53 22 Qq 54 and 55;...
Matched on
terms: oversight, rfca
Committee recommendation
90match
#28 - Department lacks an overall HM Treasury compliant financial framework for RFCAs.
The Department told us that over the last two years it had strengthened its financial oversight of the RFCAs and that monthly conversations between finance teams meant that it understood performance and risks.45 However, the Department did not have an overall financial framework for the RFCAs which complied with HM Treasury requirements. In April 2022 the Department asked...
Matched on
terms: governance, oversight, rfca
Committee recommendation
90match
#1 - Committee initiated inquiry into MOD oversight and support of Reserve Forces’ Associations.
On the basis of a report by the Comptroller and Auditor General, we took evidence from the Ministry of Defence (the Department) and the Council of Reserve Forces’ and Cadets’ Associations (the Council) on their oversight and support of the Reserve Forces’ and Cadets’ Associations (RFCAs).1
Matched on
terms: oversight, rfca
Committee recommendation
78match
#15 - Primary legislation for new RFCA NDPB thwarted by lack of parliamentary time.
One of the two headline recommendations in the Department’s 2019 review of the RFCAs was to regularise and streamline the Council and 13 RFCAs into a single NDPB. This would provide a clear governance structure that aligned with government policy to transmit, delegate, implement and enforce decisions. However, creating an NDPB requires primary legislation, and the Department’s earlier...
Matched on
terms: governance, rfca
Committee recommendation
74match
#25 - Unanticipated VAT liability reduced RFCA volunteer estate maintenance funds.
The Department had not anticipated that the RFCAs would be liable to pay VAT on work done through the FDIS contract, which has resulted in the RFCAs having had less money available for maintenance than expected. The Department explained that the crux of the issue was ownership of the estate which had been built up over 100 years...
Matched on
terms: oversight, rfca
Committee recommendation
73match
#196 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
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...
Matched on
terms: governance, oversight
Committee recommendation
70match
#5 - Integrate volunteer estate needs into defence investment plan and report on RFCA VAT progress.
The Department does not have a modernised and fit-for-purpose volunteer estate to support the enhanced roles of the reserves and cadets. The reserve training sites are the basis for mobilising the reserves, while having accommodation for thousands of cadet units to operate across the UK provides an important, nationwide presence. However, the volunteer estate has been in a...
Matched on
terms: rfca
Committee recommendation
66match
#20 - RFCA service agreements improved, but lack clear escalation processes and accountability culture.
In recent years the Department has improved the quality of the five service level agreements (SLAs) that it has with the Council, which set out what the armed forces and Department require the RFCAs to deliver each year. The Department reviews progress against the SLAs three times a year, and it told us that this has provided discipline...
Matched on
terms: rfca
Committee recommendation
66match
#16 - Establishing new RFCA NDPB remains preferred route, legislation anticipated in 2026 Armed Forces Bill.
The Department confirmed that establishing an NDPB remained its preferred route forward. This would facilitate a streamlined organisation, simplify back-office functions and clarify accountabilities. The Department said that the next opportunity for the necessary legislation would be in the Armed Forces Bill, which it is obliged to update by the end of 2026.24
Matched on
terms: rfca
Committee recommendation
66match
#6 - Implement HM Treasury-compliant financial framework, publish timely RFCA accounts, and ensure future compliance.
The Department’s arrangements for monitoring and reporting on the RFCAs’ financial performance are inadequate. The RFCAs’ accounts have been produced very late in recent years. The Department published the RFCAs accounts for 2020–21, 2021–22 and 2022–23 together, in October 2024, which means that some information about the Council and the RFCAs’ financial performance was not publicly available until...
Matched on
terms: rfca
Committee recommendation
65match
#3 - Update Committee on progress establishing new NDPB for cadet and reserve forces.
The Department has not secured the legislative slot it needs for its preferred route forward, of streamlining the 13 RFCAs and the Council into a non-departmental public body (NDPB). Creating an NDPB requires legislation. However, the Department’s earlier plan to rationalise the RFCAs into an NDPB, which would simplify back-office functions and clarify accountabilities, was thwarted by a...
Matched on
terms: rfca
Committee recommendation
62match
#27 - Some RFCA financial reporting failed to comply with HM Treasury guidance.
Some of the RFCAs’ financial reporting has not complied with HM Treasury guidance and International Financial Reporting Standards. For example, the RFCAs’ accounts have not included a cash flow statement, nor have they correctly disclosed a defined benefit pension scheme for employees. Non-compliance with these rules has created an inconsistency in the financial reporting between the Department and...
Matched on
terms: rfca
Committee recommendation
57match
#24 - 3rd Report - Protecting built heritage
Publicly owned heritage assets are too often allowed to deteriorate, with responsibility spread across departments, weak compliance with existing protocols and no effective mechanism to enforce minimum standards. While the government has acknowledged the need to improve oversight, this must now be matched by a more robust and accountable framework. The government must lead by example by ensuring...
Matched on
terms: oversight
Committee recommendation
53match
#26 - Department consistently failed to publish Council's Annual Report and Accounts promptly.
For the past four years, the Department has failed to publish the Council’s Annual Report and Accounts in a timely manner, and the Department acknowledged that the process was much longer and more protracted than it would like. It published the accounts for 2020–21, 2021–22 and 2022–23 together in October 2024, which meant that some information about the...
Matched on
terms: rfca
Committee recommendation
53match
#22 - Volunteer estate in managed decline, requiring optimisation programme to dispose and modernise sites.
The Department said that the volunteer estate was a critical enabler for it to deliver the ambitions for increasing the numbers of reserves and cadets set out in the SDR. However, the Department told us that the estate had been in a state of managed decline, and that it had too many sites, some of which are not...
Matched on
classifier match
NAO recommendation
51match
Managing FCDO’s overseas estate
FCDO should review its estates governance structure to ensure that it is working effectively. FCDO should review whether its new ESND structure is achieving the intended benefits and identify whether any further improvements are necessary to ensure effective oversight of its overseas estate.
Matched on
terms: governance, oversight
Committee recommendation
49match
#198 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
The sheer persistence of this problem in the face of various government initiatives over the years, suggests that there are significant organisational issues or structural issues or both in UK financial services and the relationship between financial services and the financing of industry. In these circumstances, we are not convinced that such changes in regulation as have been...
Matched on
classifier match
Committee recommendation
49match
#180 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We heard from witnesses representing wholesale business and specialist service providers that the Consumer Duty duplicated pre-existing fiduciary duties and other regulatory requirements that govern their relationship with clients. They told us that this introduced either additional compliance, or new requirements to evidence pre-existing duties. State Street told us: “Some market participants (e.g., asset managers) were already subject...
Matched on
classifier match
Committee recommendation
45match
#195 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Cumulatively, we were told these issues introduce significant frictions for firms, which in aggregate risk constraining growth across the sector. We heard that aspects of the UK’s regulatory regime that are more costly and complex than competing jurisdictions negatively impact on the perceived attractiveness and international competitiveness of the UK as a global financial centre .
Matched on
classifier match
Committee recommendation
45match
#176 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We received a considerable amount of evidence critiquing the FCA’s implementation of the Consumer Duty. The Consumer Duty came into force on 31 July 2023. 268 The FCA stated that a key outcome of it was for “consumers to have confidence in retail financial services markets, with healthy competition based on high standards and firms focused on delivering...
Matched on
classifier match
Committee recommendation
45match
#3 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
There has been a significant degree of ‘mission creep’ as both regulators appear to have increasingly expanded the range of their activities into areas of business management that are outside their core responsibilities. This has increased bureaucracy and imposed significant monetary and resource demands on firms. We recognise that this trend is, in part, attributable to the varying...
Matched on
classifier match
Committee recommendation
45match
#23 - Future estate optimisation phases lack secured funding and a firm completion timeline.
The Department has planned two further phases of the estate optimisation programme. It envisages these will consolidate some sites, establishing multidisciplinary super reserve centres with additional facilities such as car parking, accommodation and feeding facilities.34 However, the Department has not yet secured funding for these phases of the programme, and it was unable to give us a firm...
Matched on
classifier match
Committee recommendation
44match
#182 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Some witnesses told us that the uncertainty around the application of Consumer Duty had driven a risk-averse approach. Monzo told us: “Consumer Duty’s ambiguity drives risk-aversion” and “the lack of clarity around their application is prompting banks and fintechs to become increasingly risk-averse, fearing potential non-compliance.” 280 David Postings also told us that the Consumer Duty had reinforced...
Matched on
classifier match
NAO recommendation
44match
Government Shared Services
c) The Cabinet Office should streamline its central governance arrangements so that they avoid duplication and unnecessary work for departments.
Matched on
terms: governance
Committee recommendation
41match
#194 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Cultural change is key, and this must be set from the top. A culture of risk -aversion has led to a proliferation of regulatory activity that is duplicative and complex. We were told that the regulators do not prioritise the requests they make of firms and have overseen a proliferation of the activities they regulate, beyond their core...
Matched on
classifier match
Committee recommendation
41match
#193 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
The introduction of the secondary objective has increased the regulators’ focus on the impact that their activities have on growth and international competitiveness, but it has also brought into relief long-standing issues that limit or introduce frictions to firms’ ability to grow, innovate , compete, and attract investment.
Matched on
classifier match
Committee recommendation
41match
#190 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We welcome the FCA’s review of its handbook rules following the introduction of the Consumer Duty. However, we also recognise the cost and complexity created by layering new regulation onto similar existing requirements.
Matched on
classifier match
Committee recommendation
41match
#186 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
On 29 July 2024, the FCA launched a Call for Input to review how it can simplify its regulatory requirements following the introduction of the Consumer Duty. The FCA stated that it was aimed at identifying where it can refine its retail conduct rules and guidance and address any potential areas of “complexity, duplication, confusion, or over-prescription, which...
Matched on
classifier match
Committee recommendation
41match
#185 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
The Economic Secretary told the Committee that the Government had engaged with the FCA over some of these issues, and stated that: “On the consumer duty, we have asked the regulator to look at the rule book and see where duplication is. If we are asking firms to focus on outcomes, we cannot have an outcomes approach and...
Matched on
classifier match
Committee recommendation
41match
#181 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
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...
Matched on
classifier match
Committee recommendation
41match
#28 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We recognise that thresholds represent an essential tool for regulators to differentiate between certain types and sizes of firms and apply specific regulation proportionately. However, we received evidence that such thresholds can constitute ‘cliff edges’ which may hinder smaller firms’ ability to grow. We encourage the Government to work with the Bank of England and FCA to explore...
Matched on
classifier match
Committee recommendation
41match
#27 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
The FCA does not do enough to distinguish between firms that cater to wholesale and retail markets, or market segments in its regulation and supervision. Consequently, this has imposed unnecessary burdens and frictions on firms that could constrain their ability to grow.
Matched on
classifier match
Committee recommendation
41match
#23 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
There is a substantial discrepancy in the quality of supervision received by the largest financial institutions and the rest of the sector. Whilst it is right that the regulators prioritise the supervision of systemically important firms, this must not come at the expense of the support offered to non-systemic firms, which risks harming the ability of small and...
Matched on
classifier match
Committee recommendation
41match
#22 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We are concerned by evidence which indicated that there are inconsistencies in the quality of supervision. Firms should expect consistency in the staff that supervise them and supervisors who understand their business.
Matched on
classifier match
Committee recommendation
41match
#21 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We recognise that there are differences between the regulatory and financial systems in the UK and Singapore, but we consider that there are valuable lessons to learn from Singapore’s approach which could assist foreign firms in navigating the UK when thinking about locating new business here. As set out by the PRA, the FCA and the PRA should...
Matched on
classifier match
Committee recommendation
41match
#15 - 3rd Report - Protecting built heritage
The government should review the effectiveness of the current institutional landscape for heritage, including the division of responsibilities between Historic England, English Heritage and other funding bodies. It should assess the case for greater streamlining, or even the merging of organisations, and explore the potential for reducing administrative burdens, bringing expertise together, and improving the accessibility and impact...
Matched on
classifier match
Committee recommendation
41match
#5 - Mandate a dedicated Scottish representative on the permanent Industrial Strategy Council in future legislation.
We welcome the establishment of a permanent Industrial Strategy Council when parliamentary time allows. However, while we acknowledge that there has been engagement between the council and Scottish stakeholders, we are concerned that the absence of a dedicated Scottish representative limits the Council’s ability to understand Scotland’s distinct economic and constitutional landscape. When legislation to create a permanent...
Matched on
classifier match
Committee recommendation
40match
#183 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Some witnesses told us that the subjectivity of the Consumer Duty has made international investors more hesitant to invest into the UK. UK Finance told us that, for the banking sector: “the subjective nature of the Consumer Duty generates uncertainty and creates nervousness for investors.” 282 The Investment Association told us that: “the process of implementing the policy...
Matched on
classifier match
Committee recommendation
40match
#179 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
However, we also heard from a number of witnesses that implementing the Consumer Duty has been difficult due to, as the Investment Association suggested, “the ambiguity of the rules” and the lack of clarity provided by the FCA. The Investment Association told us that obtaining a clear understanding of FCA expectations has been “challenging.” 274 Andrew Griffith MP...
Matched on
classifier match
Committee recommendation
36match
#199 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
We received limited evidence on what the FCA and PRA could do to facilitate growth in the wider economy, or what changes could be made to regulation that would impact on investment in the UK economy as a whole. We believe that this is indicative of a gap in the evidence base for policy makers and rule makers...
Matched on
classifier match
Committee recommendation
36match
#192 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Firms have told us that uncertainty around the FCA’s expectations on the Consumer Duty, including over which markets and customers it applies to is causing them to take an overly risk-averse approach to complying with the Duty, adding unnecessary volume to an already high burden of compliance. The FCA must engage with firms to identify the key drivers...
Matched on
classifier match
Committee recommendation
36match
#191 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
It has been almost two years since the Consumer Duty was introduced—the FCA must work at pace to remove redundant or duplicative rules and requirements to provide firms with the certainty and clarity they need to maximise the Duty’s benefits.
Matched on
classifier match
Committee recommendation
36match
#189 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
The FOS and the FCA’s review of the redress system must result in clear actions setting out how they will ensure that there is a consistent interpretation of regulatory requirements associated with the Consumer Duty.
Matched on
classifier match
Committee recommendation
36match
#188 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Should the FCA fail to address concerns about the Consumer Duty requirements there is a risk that the FOS may inadvertently fill this gap, potentially creating inconsistencies in interpretation of the Duty’s application.
Matched on
classifier match
Committee recommendation
36match
#187 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
The FCA’s implementation of the Consumer Duty has introduced considerable uncertainty for domestic and international firms operating in the UK. This uncertainty is driven by a lack of clarity on the FCA’s expectations as to how firms should comply with the Consumer Duty, including which markets and customers it applies to.
Matched on
classifier match
Committee recommendation
36match
#184 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
There was also considerable concern expressed around the way in which the Consumer Duty might interact with the FOS’s rulings. The FCA and FOS’s Call for Input on the redress system acknowledged: “A mass redress event could be triggered by differing views of how the FCA rules apply. Moving to outcomesfocused regulation (like the FCA’s Consumer Duty) has...
Matched on
classifier match
Committee recommendation
36match
#177 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
However, whilst witnesses supported the underlying objective of the Consumer Duty, they told us that its implementation by the FCA has generated considerable uncertainty. We also heard a range of concerns about the impact of Consumer Duty, specifically that the FCA has provided insufficient clarity around how it expected firms to comply with the Duty, and that it...
Matched on
classifier match
Committee recommendation
36match
#30 - 2nd Report - Growing pains: clarity and culture change required - An examination of the secondary...
Firms should be confident that compliance with regulations and the law will be sufficient to avoid mass redress events, but currently that certainty and predictability is not guaranteed.
Matched on
classifier match