Last week the FCA published an update on skilled person reports commissioned in Q4 2013/14. Of the ten reports commissioned, half related to banks, including building societies, and two to investment management firms. We have pulled together the available published data to give a snapshot of the use of skilled persons over the full year.
Overall, the picture for the full 2013/14 year in respect of the reports required by the FCA is as follows:
|
Firm Business Type |
Number of Skilled Person Reports Commissioned |
||||
|
Q1 |
Q2 |
Q3 |
Q4 |
Total |
|
| Personal Investment |
2 |
1 |
0 |
1 |
4 |
| Investment Management |
1 |
1 |
1 |
2 |
5 |
| Securities & Futures |
5 |
1 |
2 |
1 |
9 |
| Bank (incl. Building Societies) |
3 |
6 |
3 |
5 |
17 |
| Insurance Companies |
6 |
2 |
2 |
1 |
11 |
| General Insurance Brokers |
1 |
1 |
2 |
0 |
4 |
| Home Finance Business / Mortgage |
0 |
0 |
1 |
0 |
1 |
| Professional firms |
0 |
0 |
0 |
0 |
0 |
| Credit Union |
0 |
0 |
0 |
0 |
0 |
| Other |
1 |
0 |
0 |
0 |
1 |
| Total |
19 |
12 |
11 |
10 |
52 |
It appears that 9 of the 52 reports were commissioned by the FCA direct under the power introduced by the Financial Services Act 2012. Banks remain the firm type of greatest focus, followed by insurance companies and then securities & futures firms.
Although the number of skilled persons reports is less than half the total disclosed in respect of the 2012/13 year, that total (113 reports) covered prudential as well as conduct issues. Even so, when one adds in the PRA data (see further below), the total number of skilled person's reports commissioned in 2013/14 by PRA and FCA is, at 85, still considerably lower than in 2012/13. This may to some extent be a reflection of the increasing use being made by regulators of attestations.
In terms of types of work, governance, controls and risk management accounted for 44% of the work required by the FCA, and conduct of business issues for just under 33%. Governance, controls and risk management also accounted for just under half the PRA commissioned reports.
| FCA Conduct Rating / Categories/Lots of Skilled Person Report |
Category of firm |
||||
|
C1 |
C2 |
C3 |
C4 |
Total |
|
| Client Assets |
1 |
1 |
0 |
3 |
5 |
| Governance, controls and risk management framework |
2 |
12 |
3 |
6 |
23 |
| Conduct of Business |
5 |
6 |
1 |
5 |
17 |
| Financial Crime |
0 |
2 |
1 |
4 |
7 |
| Total |
8 |
21 |
5 |
18 |
52 |
The updates also identify the skilled person firms appointed and the type and number of reports they have been commissioned to prepare. Not entirely surprisingly, the accountancy firms account for the lion's share of the appointments, at least in number. The cost of the appointments is not disclosed, although the FCA's Annual Report will likely provide further details in aggregated form.
Of the 33 skilled persons reports commissioned by the PRA in 2013/14 (but note that these figures are only to 28 February 2014), 20 related to banks, and 13 to insurance companies. The details of these are as follows:
|
PRA Rating / Impact Categories/Lots of Skilled Person Report |
PRA Impact category |
||||
|
1 |
2 |
3 |
4 |
Total |
|
| Governance, controls and risk management framework |
6 |
3 |
2 |
5 |
16 |
| Data and IT infrastructure |
1 |
0 |
1 |
0 |
2 |
| Prudential – Deposit-takers and Recognised Clearing Houses |
5 |
0 |
1 |
1 |
7 |
| Prudential – Insurance |
1 |
6 |
0 |
1 |
8 |
| Total |
13 |
9 |
4 |
7 |
33 |
The PRA only recently began commissioning skilled person reviews in respect of data and infrastructure, in Q4 2013/14. With international regulatory concern about cybercrime continuing to increase, skilled persons seem likely to be continue to be mandated in this area.
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Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.