The Practitioner Panel reports that its principal functions are:
- To monitor FSA’s efficacy as seen by industry;
- Communicating issues of general concern to FSA;
- Responding to FSA when requested with the practitioner view on
key regulatory issues;
- To contribute a broad industry view on the formation of
FSA’s policy. The Panel seeks to exercise influence in a low
profile way at senior level, although it can take a higher profile
when necessary and make formal representations as needed.
The Panel Chairman regularly meets the Chairman of
FSA, although there are frequent informal contacts with directors
and senior executives who attend its meetings and take informal
soundings.
Consultation
The Panel is consulted on FSA’s emerging
policies. It reviews formal consultative papers prior to
publication, but does not provide a formal response to them as this
is better left to the industry. The Panel receives feedback from
FSA at the end of each consultation process.
Concerns The Panel has expressed some
concerns which are as follows:
- FSA’s move to risk based regulation, and the resulting
proportionality of approach, needs to be translated from policy to
operations;
- The process and quality of some of FSA’s research which
it uses to back change needs to be improved;
- The way in which a Financial Ombudsman Service decision may
have the effect of creating a new rule without either
pre-consultation or the governance process which FSA must observe,
is of some concern;
- To ensure that FSA’s procedures focus on material rather
then trivial matters.
Contact invited
The Panel invites firms to contact it in respect of
significant matters where it is felt that its involvement could be
productive.
For further information please contact Simon Morris
on +44(0)20 7367 2702 or by e-mail at simon.morris@cms-cmck.com.