FCA week in review November 20 – 24, 2023

BNPL lenders, pensions value for money, and two speeches on the importance of organizational culture.


Credit lenders Morses Club Limited and Shelby Finance Ltd (trading as Dot Dot Loans) have entered administration. Ed Boyle and Robert Spence of Interpath Ltd have been appointed as joint administrators.

The FCA is completing its assessment of EEA-based firms that are operating in the UK while offering unregulated buy-now-pay-later (BNPL) products. The Temporary Permissions Regime, which allowed the firms to operate in the UK after Brexit while transitioning to the full UK regulatory regime, is coming to an end, and the FCA issued a reminder that exempt BNPL products are not under its remit.

Rules and consultations

A consultation on detailed rules for a new Value for Money pensions framework is to be launched in the spring of 2024. The aim is “to shift the focus from cost to longer-term value”.

The FCA and Bank of England have reviewed the Memorandum of Understanding which provides the framework for supervisory co-operation. The process included consulting with FMIs to review their co-operation regarding market infrastructure in 2022.

The conclusion is that the MoU’s arrangements for co-operation remain effective and that in the main there has been strong co-ordination and material duplication has been avoided.

Speeches and media

Sheree Howard, the Executive Director of Risk and Compliance Oversight, made organizational culture the focus of the keynote speech at XLoD 2023 in London, an event we reported on.

She said rising pressures meant judgments on risk had to be exercised more carefully than ever, but this should not lead to a drop in standards. Creating a culture in which employees feel free to speak up is key, and there needs to be a cohesive approach to the three lines of defense. And DEI measures need to be seen as central to creating the kind of culture needed.

Organizational culture was also the focus of a speech given by Emily Shepperd, Chief Operating Officer and Executive Director of Authorisations at City & Financial’s Culture and Conduct Forum. Shepperd re-emphasised many of the points made by Sheree Howard at XLoD, buit with particular reference to efforts to raise the bar under Consumer Duty.