2017年-FCA英国金融行为监管局_fsa_rcro_2012_124页_5mb

Retail Conduct Risk Outlook Summary (2012)

Core Content

The Retail Conduct Risk Outlook (RCRO) 2012 is a report by the Financial Services Authority (FSA) outlining the key retail conduct risks that firms and consumers should be aware of in the next 12-18 months. It provides a comprehensive analysis of the economic and regulatory environment influencing the retail financial services sector and identifies the 15 highest priority conduct risk areas.

The report is structured into two main chapters: Chapter A discusses the environmental and macroeconomic context, while Chapter B presents the identified risks. It also highlights that some risks previously considered high priority in 2011 are no longer the focus, while others remain critical for consumer protection.

Main Viewpoints

Economic and Regulatory Environment

• Macroeconomic Conditions: The UK economy experienced low growth in 2011, with real household income declining due to inflation, tax increases, and reduced wage growth. The savings ratio fell from 2009 onwards but showed a slight increase in 2011 due to precautionary saving.
• Debt and Investment Trends: Households have seen a shift towards safer assets such as currency, deposits, and insurance, while investment in equities has declined. Despite low interest rates, mortgage repayment difficulties may increase.
• Regulatory Impact: Regulatory changes, including the implementation of RDR (Retail Distribution Review), Solvency II, and the Mortgage Market Review, are creating significant pressures on firms and affecting their business models.

Key Consumer Trends

• Consumer Confidence: Remains low due to economic uncertainty, fiscal consolidation, and high unemployment, particularly among younger age groups.
• Product Demand: While product penetration has not changed significantly, certain product types (e.g., savings) have seen different trends. Consumers are increasingly focused on debt reduction and consolidation.
• Financial Pressure: Affects spending and saving habits, with some consumers shopping around for cheaper financial products rather than reducing holdings.

Key Risks Identified

1. Aligning business models to the fair treatment of consumers

• Risk of poor service due to cost-cutting measures.
• Risks from changes in business models in life insurance and retail banking.

2. Complexity in retail investment products and services

• Mis-selling risks in complex products like structured investments, unregulated collective investment schemes, and exchange-traded products.

3. Firms' responses to regulatory and legislative change

• Impact of RDR, Solvency II, and the Test Achats ruling on gender pricing in insurance.

4. General insurance

• Consumer focus on initial premiums may lead to dissatisfaction.
• Risk of products of limited value and payment protection insurance mis-selling.

5. Governance of funds in life offices

• Risk of inadequate disclosure and management of fund risk profiles.

6. Host authorised corporate directors

• Risk of consumer detriment due to lack of specialist skills in managing complex funds.

7. Inadequate complaints handling

• Risks in complaints handling by major banks and Payment Protection Insurance (PPI) redress.

8. Investment propositions

• Risks associated with the use of platforms and centralised investment propositions.

9. Investment risk profiling

• Ongoing risks of ineffective customer risk profiling across various firms.

10. Investor compensation protection

• Risks of inadequate investor protection if an investment firm in another EEA country fails.

11. Mortgages

• Risks of unfair mortgage terms, product innovation, and treatment of customers in arrears.

12. Pensions and retirement planning

• Risks in the Self Invested Personal Pension (SIPP) market and decumulation options.

13. Product bundling

• Risks of bundled investment and deposit products leading to poor consumer outcomes.

14. Projections

• Risk of firms not adjusting projected returns in line with actual performance.

15. Systems and controls weaknesses in the network model

• Risks of inadequate internal controls, especially as RDR implementation deadlines approach.

Risks No Longer Considered Highest Priority

• Structured deposits
• UCITS IV
• Tax changes and their implications

These areas are still relevant, but not among the top 15 risks in 2012.

Equality and Diversity Considerations

The FSA considers equality and diversity in its analysis, but the report does not explicitly address the implications for minority groups with protected characteristics such as age, gender, and disability.

Conclusion

The RCRO 2012 aims to help firms understand the risks they face in their interactions with retail customers and take appropriate action to mitigate them. It serves as a guide for regulatory focus and is part of the FSA's preparation for the transition to the Financial Conduct Authority (FCA). The report emphasizes the importance of aligning business models with consumer needs, improving transparency, and ensuring effective complaint handling and risk profiling.