This type of guidance is clearly well-intentioned and likely to be welcomed by consumers, but also it demonstrates the FCA's willingness to continue with prescriptive regulation.
For the time being, a lengthy set of policy initiatives requiring potentially significant operational changes may not be the most appealing advertisement for businesses considering expansions or entering into the UK market.
Instead, the financial services market may be wishing for certainty and stability and some time back to focus on driving business and growth rather than operationalising more regulatory initiatives.
Whitney Simpson, of counsel, Jonathan Charwat, senior associate, and Matthew Griffith, partner and head of the financial services team, at RPC