Oh to be in the UBS compliance team this week. With news that another “rogue trader” has slipped under the radar in such spectacular fashion—at a time when the world’s banking system is in such a fragile state—the spotlight is thrown yet again on governance
Whether as deterrent or detector, the introduction of the Financial Services Authority (FSA) mobile recording regulation PS10/17 on Monday 14th November 2011 will fill an important gap in compliance teams’ and the FSA’s armoury.
So what will happen after 14th November? The FSA has two main approaches to supervision: monitoring and “thematic surveys”.
Thematic work involves analyzing a product, market or practice, to assess risks within a particular market or sector and is used to complement firm-specific monitoring. On average over the last six years, they’ve undertaken over four a year. In the current
environment it’s a safe bet that this number will rise.
When I met the FSA last month they raised the possibility of a thematic survey into banks’ implementation of mobile recording. This is not surprising. Over the last three years, they have faced persistent industry pushback to the regulation. Yet this is
no minor communication media. Mobiles have, and will increasingly be, an intrinsic part of working life. Financial services is no different in this respect to any other industry.
The message is clear: don’t treat this as a box-checking exercise. Make sure your policies, practices and technology meet the FSA’s compliance requirements. Otherwise, you can expect to see reputational damage occur time and time again.