This column in its various guises has come live from some interesting places over the (remarkably) years. The Eurostar, Bucharest, Seattle, Managua. But today we reach a new level as I type whilst holed up in the remote, deserted outpost that is the city of London. A place where EC3 used to be a post code rather than a measure of the number of people about. Although James has just turned up to play with the new phones. So that makes it four.
Bit of a bumper week this week so strap yourselves in.
Rash decision making
I am sure it came as much a shock to you as to the rest of us to discover last night that leading social justice warrior Marcus Rashford also plays football. Who knew? And, whilst this missive revels in an opportunity to take a contrary view on most issues, and would dearly love to find a way to suggest that St Marcus isn’t all that, it is quite hard. He is intelligent, seemingly articulate (although I am not fully convinced his social media isn’t someone else) and gets things done. But much more importantly he so very clearly really p****s off Bozzer, Hancock and co. So my main concern is one of the most efficient distribution of national resources. Because what with Harry Kane – who I grudgingly have to accept is quite good at football – Raheem, Sancho and various other Icelandic model botherers, we sort of don’t need St M down Wembley way. But, given the daily demonstrations of complete governmental deficiency on display, we really could do with him round Westminster. So, how do we make this happen? If only we had a Presidential election coming up.
The James Livett not fun stuff intrusion
Riled by the new celebrity his colleague Ms Hobbs has gained in recent weeks, the nations nattiest dresser is keen to get in on the action. So he provides the following morsels of the mundane for your delectation.
- There will be a new corrections form coming out imminently. Now this could be wildly exciting, but apparently it is not that sort of “correction”. The aim here is to try and streamline a process that is taken up to 10 days to complete. Worthy, but…
- Also imminent are instructions on how the deferred scheme will operate in the context of EU policyholder/EU risk business after the end of the year. No words.
Some counter Hobbservations
Not to be out done, Jackie has seen that montage of monotony and risen it as follows.
- Bulking Lineslips (with which, you will have noticed, Ms Hobbs has become disturbingly obsessed). Discussions with LIC SA and the LMA continued this week regarding requirements effective from 1st January. We have requested that practical guidance be provided to the market, which we understand will be towards the end of next week (there are a lot of instructions due out next week. Could be a good one to be on holiday for. And, as luck would have it, I am).
- Lloyd’s has issued details of the changes being made to the terms of trade for delegated authority business (estimated for next year). There are a number of sessions being held by Lloyd’s on the detail, as per the attached circular sent out this week. We hope to have completed work on the pre-requisites to be presented to Lloyd’s shortly, details of which will be shared with our members. And, let me tell you, LIIBA’s pre-requisites are going to be like Mikel Arteta’s “non-negotiables”. And Lloyd’s don’t want to do an Ozil.
- To finish on a positive note (we’ll be the judge of that), Lloyd’s is implementing a new system in Q4 this year to make it easier for coverholders to report on CAT losses affecting the US, Canada, Caribbean and Australia (will it be an UCCA form? – kids – ask your grandparents). This means multiple requests being received from different managing agents will be a thing of the past. We will be releasing information on the detail in the next few days.
Post your thoughts – but only if they’re good or else
I believe there is still time for you to complete the most important task since lockdown began and that is to tell Post magazine how fantastic your trade association has been by completing its survey. Now, I am conscious that part of our role as your representatives is to ease the burden wherever we can, so can I suggest the following answers?
Questions 3 & 4 – Very Well
5 – A seamless switch to remote working whilst upping its game in terms of the support it provides
6 – very well
7 – remember how we got FCA to go easy on client money rules at the beginning? And we were pretty much the only body to actually mention clients in the wake of the BI test case result.
8 – Yes
9 – No
10 is thus irrelevant
11 – No
12 – N/A
13 – 15 No
16 – don’t answer him Pike
17 we will leave to your own conscience
18 – Can I suggest “more of the fantastic, hilarious emails we get each week rounding up events”?
19 – James’s shirts
You know it makes sense. And you also know we know where you live. Just sayin’.
3:10 to EULA
Just so you are aware, we remain in discussion with Lloyd’s over the proposed End User Licence Agreement (EULA) for the artist formerly known as DA SATS (it is called something else now to try and style out the fact that DA SATS never really worked – DDSM or something). We are still working through a number of issues with the agreement so look out for more detail on this shortly. Probably best not to sign it for now if asked.
A distrumpian vision
After fluking a prediction that Donald Trump would become President about a year before he did, I know I have amongst some of you an undeserved reputation as some sort of US politics expert. And up until now I have been avoiding a prediction because, along with everyone else, I haven’t got a ******* clue what is going to happen. All I can say with any degree of certainty is that this time next week the Donald will be in the White House and the result will be in the courthouse. And I expect both to stay put for some time to come.
Descending from the Stratfordsphere
Two items to update you on from FCA. The first is, even by their own fine standards, baffling. But here goes.
Many of you will be aware that we issued the first phase of the Covid-19 Impact Survey in June, covering around 13,000 firms across 15 Supervision portfolios (Tranche 1), and then rolled this out to a further 9,500 firms in 21 portfolios (Tranche 2) at the beginning of August. The survey is helping us to obtain a more accurate view of the impact of Covid-19 and supporting our work to mitigate risks of harm to consumers, the market and competition within it. As advised previously, we repeated this survey for Tranche 1 to understand the change in firms’ financial positions with time, and are now doing the same for Tranche 2.
We are planning to send this survey to the relevant firms in Tranche 2, some of which may be members of your associations, on one of the following dates:
Batch 1: to be sent on 3 Nov – response due by 27 Nov
Batch 2: to be sent on 5 Nov – response due by 1 Dec
Batch 3: to be sent on 6 Nov – response due by 2 Dec
Batch 4: to be sent on 10 Nov – response due by 4 Dec
We will send a warm up/introduction email to all the firms at least a day prior to them receiving the survey.
We are including an extra two questions to cover the potential impact of Brexit, as the end of the transition period is nearing. Therefore, this repeat survey will include 12 questions in total, designed to give us information about the following important areas:
- Liquidity/ cash availability and needs
- Recent financial performance
- Scale of business activity
- Access to government schemes
- Impact of Brexit
The survey will be sent to all firms in the following Tranche 2 portfolios unless they satisfy specific exclusion criteria:
- Exchanges
- Asset Management
- Wholesale brokers
- Wholesale banks
- Principal trading firms
- Wholesale (other)
- Life third party administrators
- Multilateral Trading Facilities and
- Organised Trading Facilities
- Alternatives
- Benchmarks
- Claims management
- Lloyd’s & London market intermediaries
- Retail mortgage lenders
- Mortgage third party administrators
- Lifetime mortgage providers
- Debt advice firms
- Non-bank lenders
- Mortgage intermediaries
- Motor finance providers
- Retail finance providers
- Price comparison websites
Firms will be emailed a link to complete the survey online (not through Gabriel). It is designed to be easy to complete even via a mobile phone and we expect that most firms will not need more than an hour to complete. The link we send to firms will be unique to each firm. If firms need a different individual within their organisation (or a third party who works for you, e.g. a consultant) to answer and submit the survey, the link can be forwarded to the required person.
Completion of the survey is mandatory under section 165 of the Financial Services & Markets Act (FSMA) 2000. We may exercise our powers under FSMA for firms who do not respond. We have designed this survey so that it is quick and simple to complete. However, if due to exceptional circumstances a firm cannot access its financial information, they will need to ensure that they complete the questions where the relevant information is available.
At the FCA, our core responsibilities include protecting consumers and enhancing the integrity of the UK financial markets. We know that financial stresses can put additional pressure on firms and so we are seeking to understand the effect Covid-19 is having on the finances of the firms we regulate and better guide our supervisory actions.
And breathe.
So, basically, if you got a survey from FCA in August, expect a follow up one soon. And if you got a survey from FCA in June you will already have another one now. Good luck with that. Let us know if we can help.
Slightly more straightforwardly they have also written asking us to remind you to update your data on their new Directory system via Connect. You have until end March to do this but they will start publishing the data you have submitted so far from 14th December.
Criminal stupidity
Regardless of what happens next Tuesday, the closest contest of the week is undoubtedly that between Graham Nelson and Mark Cooper for the title of most idiotic criminal of the year. Graham got off to a good start by actually getting away without a ban when he claimed that the only reason that he was driving whilst twice the legal limit was that his girlfriend had a medical emergency and then that she had died a few days later. It all went a bit **** up however when the police dropped round his house and she answered the door. Although he probably deserves some marks for the fact that no one at the time of his trial seems to have thought to actually check what he was saying was true – which, as subsequently demonstrated, really would not have been that hard. Morse probably left that to Lewis.
Mark, on the other hand, is in police custody because, when attempting to rob a restaurant, he eschewed the traditional approach of emptying the till and doing a runner in favour of the more avant garde eating half a cheesecake and falling asleep. Stupid. But, then again, mmmmm cheesecake.
A close call, so I am going to leave it up to you. Text either “Graham” or “Mark” to #83478. Texts cost £983 plus your standard network rate. Please check with the bill payer before you text. Please don’t text ever because you vote may not be counted but you may still be charged. All proceeds go to the LIIBA Xmas party fund.
On a point of order, I should confirm that this Mark Cooper is not the Chief Market Development Officer for Lloyd’s Europe. At least I don’t think it is…
That is it. I am off to chase tumbleweed down Leadenhall St.
LIIBA – re. Lloyd’s Bulletin Y5311 Conditions of Trade for Delegated Authorities Data