Although the ease with which a supposedly sophisticated wholesale financial services sector has been undermined by a bunch of people off Mumsnet, or whatever, is equal parts delicious and terrifying.


And so it came to pass that Priti Patel was forced to reluctantly announce a policy which she didn’t believe in to a House of Commons that had been told about it already by the Prime Minister. Hoo-millee-ate-tin.

Yes, now we know that alongside our Australian style points system that determines the criteria upon which people are allowed to enter the country, we now have an Australian style quarantine system to foil the attempts of the few people who qualify.  So what else are we going to steal from our upside down cousins?  An Australian style wine industry so that people with boats with outboard motors need never run out of fuel?  An Australian style cricket team so we can admire a figurehead who embarrassingly taunts opponents with terrible hostages to fortune (“can’t wait to get you to the Gabba Ash” – what, so you can be trounced by India’s c-team?).  Or Margot Robbie….oh, hold on…

In its original reporting of this story, which I can’t find now so you are going to have to just trust me, the Daily Mail only listed six out of the now thirty-three countries on the Government’s “red list”.  Presumably because they were the only six they thought their readers would have heard of, given that they were:

Brazil (“aren’t they the johnnies who are jolly skilful at that soccer mularkey? Not that I am a round ball man. Who’s that new chappy they’ve got? You know, the Beast of Bolsonaro or somesuch? Not quite my cup of tea but he does talk a lot of sense about this blasted virus.  He could certainly teach Boris a thing or two about standing up to scaremongering scientists!”)

Argentina (“one minor war and no world cups, doo daa.  Dashed dangerous at rugger though.  Big chaps.  Must be the corned beef”)

Chile (“you know we had the General round for dinner once when he was living over here.  Absolutely charming man.  Nothing like the au pair said he would be.  She was from Santiago you know.  And, I say, it’s the most darnedest thing.  We never saw sight nor sound of her again after that very night.  Completely vanished…”)

Portugal (“Smudger used to have a place down there.  The japes we got up to! Golfing all day and chasing the fillies at night! Don’t tell the Duchess!”)

Kenya (“The Duchess and I spent a wonderful couple of weeks there staying with old Lucky Lucan on his farm out in the bush.  Miles from anywhere.  But mum’s the word or we will all be in the soup!”)

South Africa [insert own “pining for the days of apartheid” gag here]

Strange that they left out Panama though.  Given it is where they keep their life savings.


I attended a roundtable event for trade associations this week with Nikhil Rathi – the new CEO of FCA – Executive Director Sheldon Mills and person in charge of its transformation programme Meghan Butler.  But I will stop making you all jealous now.  A few titbits.

  1. Rathi welcomed the collaborative spirit that has marked relations between FCA and trade associations during the pandemic and trusted that it would prevail after lockdown ends (in 2025).
  2. He noted that the end of the Brexit transition period had passed without operational disruption.
  3. He realises that the HM Treasury consultation on the future regulatory framework is likely to bring a revised and more stringent accountability approach for FCA.
  4. He pledged that FCA would continue to work closely with the European Supervisory Authorities and national EU regulators as well as counterparts in US and Switzerland in particular – recognising the international nature of UK’s financial services industry.
  5. The focus of FCA as we emerge from the pandemic will be on climate change and diversity and inclusion.
  6. FCA’s strive to be a more data driven regulator should allow it to cut costs.
  7. To which end, Sheldon Mills asked us to remind you about the changeover to the new RegData system.  You will have been sent the date when this will happen for you.  You need to register on the new system in order to get notifications when you have returns due.
  8. Sheldon also bigged up the new Policy, Competition and Supervision mega division as an attempt by FCA to address its main issue that nobody ever talks to each other.
  9. Meghan Butler cited better internal information sharing as a key theme of the transformation programme along with a review of how they collect and share data and the processes by which they ensure they have the right capabilities in the right place at the right time.
  10. She also promised that a key output of the programme would be a “clear and measurable articulation of what regulation can deliver for the public”.  Which will be a first.

Eine Keiner trade agreement

The second highlight of my week was to attend a meeting of European Services Forum with Christophe Keiner who headed the EU negotiating team for services.  He ran through the benefits of the EU/UK Trade & Co-operation Agreement making the following points.

  1. It was the UK that insisted on a free trade agreement rather than something more ambitious and FTAs are not a good method of reaching sophisticated agreements on regulatory co-operation.
  2. Two of the more interesting features of the agreement – the forward looking most favoured nation provision and the review of the agreement every five years – specifically do not apply to financial services.
  3. The provision for the entry and temporary stay of natural persons fully achieved EU’s objectives and is reflective of the increased standards it has negotiated with Japan and Canada.
  4. The agreement on professional qualifications was not as good as EU hoped.  Now UK and EU professional associations will have to jointly present proposals for mutual recognition to the Partnership Counsel.  Recognition is exclusively preserved for EU so individual member states cannot unilaterally grant equivalence.  Must break this to the Belgian ambassador who is still looking at ACII…
  5. The discussions over an MOU on regulatory co-operation for financial services will not cover market access and the purpose is not to deliver market access.  It is merely a method of trying to replicate the increasingly successful relationship EU has with US – to which it granted clearing house equivalence this week.

Next week we have the leader of UK delegation for his take.  Christophe had the air of a man who had triumphed (mainly because our government sacrificed services for fish).

Septic relationship

A Scottish woman has gone viral on Tik Tok by questioning some habits of the Americans such as their refusal to own a kettle.  But there are some crucial points that she has missed, I think.  Such as:

  1. Why can’t they spell?
  2. What is it about roundabouts that so intimidates them?
  3. If (with the possible exception of 1812 which doesn’t count because no one wrote an overture about it) the only war you have ever won is your own civil war – and only then because you took the precaution of being on both sides – should you be so aggressively militaristic? And before you start, the French won the revolutionary war, the Mexican war of 1848 would be like Tottenham boasting about knocking Marine out of the FA Cup (cf Grenada & the seizure of Noriega), turning up at the end after all the work has been done doesn’t count (WWI) and Russia (WWII).
  4. Isn’t Amanda Gorman signing a contract with IMG Models a bit incongruous?  You see, I told you I would find something.

Incidentally, Ms Gorman’s appearance at the inauguration led to a 1328% increase in the internet searches for “yellow coats”.  And next week, back by popular demand, BBC is rerunning every episode of Hi-De-Hi.

Livett on a prayer

James has stepped into Jackie’s shoes and provided content which is the very antithesis of his shirts, such is its dullness.  He has even provided subheadings – which I hate.  And not a pun in sight.  Poor.  But here goes.

Delinked Entries

There are approximately 24,000-line items of unpaid delinked signings recorded in DXC systems that are most likely redundant, primarily a result of subsequent duplicated presentations and mid-term broker changes. This causes issues for all.  We have agreed with the Lloyd’s Customer Representative (LMA) and Lloyd’s Corporation that DXC will perform a one-off purge (so Stalinist, I love it) to cancel unpaid delinked signings first processed in 2017.  A full communication explaining the process will be issued in the next few days.

New Correction Form

LIIBA’s BASIC and DXC have worked together to revise the Corrections process (does it involve hiring Cynthia Payne?).  This is with the ambition to reduce the time it takes to have a correction signed by XIS.  As part of this a new Correction Form has been produced and issued to the market (attached).

We have worked with DXC and will be publishing a high level report (anonymised) on our Website from February showing who is using the form and (more importantly) who is not.

This exercise/report is a pre-cursor to the planned automated process of REJECTING CORRECTIONS THAT USE THE WRONG FORM.  Implementation of the automated process will be later in 2021, probably towards the end of Q1.

With this in mind can we ask you to ensure that the new CRF is being used in your organisation.  New form is attached (yes it has macros in it).


The Part VII Programme is currently conducting Roadshows for all Coverholders and DCAs to cover the key content in v3.0 of the Coverholder and DCA Guides and highlight Post SED action required (you were lucky that didn’t autocorrect to seduction but what does it mean?).

During these sessions, the updated Complaints Handling Process is being briefed and covers the high-level approach and principles for Coverholders and DCAs to follow in handling complaints. Detailed guidance has also been developed and you can access it here.

In addition to the Roadshows, the Part VII Programme is hosting two sessions to work through the guidance in detail and answer any questions. Please register for either 1 February 13:00-14:30 GMT here or 11 February 13:30-15:00 GMT here. They will also be recorded for those unable to attend the live sessions. Please find the slides that we will be using during the session here. (SPOILER ALERT!)


All master lists yet to be downloaded will be re-issued via Forth (Road Bridge?) on Monday.  Over 100 brokers have yet to download their lists.  We have assisted the Part VII team with some additional contacts, but if you have not downloaded yours and have not received instructions please let us or the Part VII team know.


We have been working with the Part VII team and the Carrier community with regard to a process to change the Master lists and/or resolve disputes.  This has taken longer than we had hoped but we can confirm that there has been some significant progress in the last week and we hope that the proposed process(es) can be published shortly.  (is the term “master list” acceptable anymore given its obvious connection to slavery?)

Open MA and broker sessions to be scheduled, now targeting early February

Webinar nar, webinar nar, hey hey ey, good time

Just a pointer towards useful content past and present.  Grant Thornton ran a very useful session for us on data privacy this week – the recording is available on our website.   And we have a claims webinar on Friday 5th February.  Click here to register.

Time wasted

A study this week suggests that Britons in Lockdown III are doing less exercise and spending more time slumped in front of the telly.  The report suggests that this maybe because the novelty of being under house arrest is wearing off (vraiment??), although it fails to mention the fact that the weather is awful.  But in reality neither is the main driver of our increasing slothism.  It is because, as was confirmed for the umpteenth time again on Monday, that we are all just pissed all the time.  This makes for impressive reading.  7% of us have sought hospital treatment after drinking in the last year.  On average we are falling over drunk 33 times a year.  We are twice as sozzled as the Polish (and how come the Colombians are so abstemious?).  And all this just by surveying the English and the Scots.  The mind boggles what we could achieve if we brought the Welsh in too.  Stay at home.  Drink Loads. Bother the NHS.

I’m off to…don’t be silly, I am staying here and watching Hi-De-Hi.  Now, where’s the vodka?

Letter FSMA of 22 January 2021 — London International Insurance Brokers Association