Status update

Apr 24, 2024

Webinar. I am Samantha Martin-Woodgate, the community leader here at Skillcast, and I am delighted to be joined once again by Catherine Lehman. Catherine is CEO of Lehman Curlin, and as someone who previously crafted FCA business plans, Catherine maintains a keen interest in their contents and how firms interpret them. In today's 45-minute session, we will try to make the session as interactive as we can by asking a few polls, as we usually do, to understand how you are feeling, and we would also be grateful if you would participate in the Q&A section. These sessions are carefully crafted to support you. Still, it helps to understand where your pain points are and how we can provide additional guidance. Of course, these question and answer boxes are anonymous, so we will not call anyone out on specifics, so please ask questions. Let me briefly set the scene before I hand over to our expert, Catherine. In this morning's session, we are diving into the key priorities outlined in the FCA's 2022-25 strategy and exploring their implications for firms. As we approach the final year of the three-year strategy, it is essential to understand what actions the FCA is taking and what it expects from regulated firms. At Skillcast, we have closely followed these priorities and tailored some of our events and webinars to address associated challenges. We have provided wealth of guidance to our compliance community, featuring insights from industry experts who generously shared their experiences and best practice. As we delve into the FCA's latest update release at the beginning of the month, Catherine, we would love to know what aspects of the FCA update caught your immediate attention and how you perceive this impact on firms. Thanks, Sam, and good morning, everybody. I can see we have got quite a few of you on our webinar today, so that is wonderful and good to see so much interest. Do ask questions as we go. Stick them on the chat, on the messaging system here. They will come up anonymously and we will not name you, unless you want us to. Just a little bit of context before we get started, because I think it is really important when you look at the FCA's business plan and what are they saying they are going to be doing in the next 12 months, it is really important just to take into account a bit of sort of general context. What is going on in the environment, what would drive them to prioritize one thing above another thing. We have got some sort of key headlines on the slide here, which are things that the FCA has kind of pulled out. As we know, the FCA has been on a bit of a journey to try and transform itself internally to make it much more data-led. Of course, if it is a more data-led organization, that makes it a lot more efficient, hopefully, in the way that it does things. It means that it is not sending, well, hopefully not too often, sending armies of people out into our offices to go look at what we are doing because we are sending them data and they have got people remote working or working in regional offices, because we know that the FCA has got offices around the country now. They will be analyzing and interrogating the data that we send them, and they are getting really good at that now. They are getting really good at being able to see what is it that we are doing and spotting trends, spotting themes. They are really good at even being able to spot if we are not giving them the truth in our reporting now. It is something we have really got to focus on. They have long said that they want to be a more assertive regulator. They want to be outcomes-based. The Consumer Duty that we saw coming last year and that Skillcast has been talking about a lot in the last 12 months, we have seen a lot of that. There is no change to any of that. They are continuing to do that. That is a continuation of where they are trying to get to. The more general, and I think really important operating context is what is going on in the external environment, and this is driving a lot of their prioritization. You would expect it to. We have got economic uncertainty globally, not just nationally, and that geopolitical landscape really is becoming more and more challenging. That does drive how they prioritize some of their work, and that does inform what they do. We will unpack a little bit of that for you later on. Higher inflation, of course, that does have a bearing because that leads to, as it says on the slide, higher borrowing costs. That also leads to pressures on some firms, pressures on the bottom line, pressures on fixed costs, pressures on what firms are delivering and whether or not they are actually generating sufficient revenue. I know that the FCA from time to time does ask firms and say, "Well, when are you going to be cash positive?" That is not an unusual question for a new firm. It is also not an unusual question for a firm that regularly sees their regulatory capital bob up and down very close to the minimum levels required in the threshold conditions. Actually, I have seen the FCA say to some firms, "Well, actually, you have got sufficiently close to your minimum regulatory capital, you should have started invoking a wind down plan. When did you do that?" That is quite a difficult question when you are in a spot. It is really something that the FCA expects you to be on top of, and you should be joining those dots rather than not expecting the FCA to ask those questions of you and for you to say, "Oh, yes, let me come back to you." Be on top of that. I think before we move on, Sam, do we have a poll before we start the next phase? We would just like to get your feedback and input on this first poll. Just generally, what would have the greatest impact on your firm? If it is not one of those three, then feel free to add a comment in the chat, because it is always really interesting to see is there something else that is causing a bit of a pressure point on your firm at the moment. As we say in the questions here, there is a number of areas that the FCA is focusing on. It is just really interesting to see how does that affect your business and your firm and what you are doing internally. We will just give you all a few moments to vote. Pick one, any one of those. And as I say, drop something in the chat for us, if there's something that's not on this slide that you are focusing on and finding is a real impact on your business. Just a couple of. Yeah, I'll just give it a few more seconds. Nearly everyone's voted. Closing the poll now. Wow. That's really. I have to say, I didn't expect that answer, if I'm honest. I didn't expect the changes being made within the FCA to have a huge bearing on what people are doing day to day. Yes, of course, data is important, and I'm guessing if anyone wants to comment in the chat, please do. But I'm guessing maybe that's one of the biggest impacts for you. Uncertainty with the external environment. Yes, of course, I'd expect that to be quite up there. And some of you, higher inflation and borrowing costs. I can see in the chat, quite a few of you are making some comments, so thank you for doing that. Somebody's commented that they voted other because they've got an integration following an M&A acquisition. I can well imagine that's enormously time-consuming. It always is when that happens. Someone else has commented that the increase in development of AI models and financial crime defenses is having a great impact on their business. Now, that's a really interesting point, and we will come back to that one. And another comment, product challenges by the FCA. Interesting. I'm guessing that there's a bit of that around Consumer Duty because, of course, product governance and how we're structuring our products and so on. There's a huge impact coming from Consumer Duty. And there's also, even if you're not in scope of the Consumer Duty because of the product governance regulations, you have to consider that. And this is great. Some more comments coming in. I'd interpreted FCA changes to be more linked to regulatory changes, so new rules impacting firms. Yes, you would expect. Actually, we'll come back to the point about new rules and what that new landscape might look like in the next 12 months and actually possibly longer term than that. Someone else says that the FCA changes impact their compliance function, as well as for the company as a whole. It depends. Yes, of course, it depends which area of the business that you sit in. May I move on and talk a little bit? Just a quick reminder. I think if you've been coming to a lot of these Skillcast events and webinars, this slide here may not be that new to you, and that's because this is the FCA's three-year strategy. We are now in the last year of that strategy. This is going to run to end of March next year. We don't know. The FCA has so far been silent on what's going to happen after that, whether they're going to produce another strategy or what's going to happen after that. We are in the final year of this, so they are continuing to focus on these three themes. They're continuing to progress the 13 commitments that they've made under each of these three themes. I think that's quite interesting. It's good to have some consistency from a regulator. Everyone appreciates that. None of us like surprises. It's good for us to be able to just look at it and say, "Okay, so where does the FCA really think they still need to make more inroads in the next 12 months to this strategy?" What I've done on the next slide is pick out for you my top three areas that the FCA say they're going to focus on this year. I think for me, this is kind of, part of it shouldn't be a surprise to you. I don't think any of you, or I hope none of you are looking at this going, "I never expected to see such and such on there." I think it's quite interesting that these are the three that they've picked. What I'd like to do, if I may, is just unpack each of these three and we can have a little conversation about what do they actually mean by each of them. Perhaps we can go on to talk about the first one, which is reducing and preventing financial crime. I can just pick out some of the things that the FCA has been talking about there. On this slide, I've got a little bit here for you about what they're prioritizing in terms of reducing and preventing financial crime. Some of the areas that they have really picked out, and I think you might find a surprise, is, of course, we have the Economic Crime Plan that was published earlier this year, with a focus that sort of talks about reducing money laundering, preventing or recovering more criminal assets, and combating kleptocracy, cutting fraud, reducing the threat of illicit international finance. These are all things that are part of their Economic Crime Plan. What the FCA is saying for the next 12 months ahead, is that they want to focus on reducing, preventing financial crime in terms of fraud. Fraud. Fraud really is up there. It is the single biggest item that I can see the FCA is talking about, and I think that is no surprise. If we look at what they have got planned for the year ahead, you can see that they are really focusing on scams, on trying to recover assets for victims, looking at the losses suffered by those victims, trying to slow growth in APP fraud. After that, they are also talking, of course, a little bit more about money laundering. Those are the three that I have picked off. Actually, if you read through the business plan, they do also, and I nearly put it on this slide, actually, is mention sanctions. Because sanctions compliance, of course, is a really hot topic, particularly if you remember that geopolitical landscape. There is a lot of political pressure to make sure that sanctions are being adhered to. It is really, really important that we continue to keep up to date with sanctions. I know it is incredibly difficult because they do change quite frequently. But we have to be one step ahead of new sanctions as and when they come out and make sure that we are adhering to them. We will see focus from the FCA on making sure that we are adhering to sanctions, as and when they come out. This is an area of FCA focus, but actually, fraud is right up there. I think, Sam, we have been talking about that for some time in events. I think you might be on mute. Sorry. I keep coughing, so I keep putting myself on mute. Considering 40% of crime in the U.K. is fraud, I figured that this would be a big focus, and that it would just be kind of that you would talk about the distinctions between the different types of fraud. So it is quite interesting that you have put that on there twice. Yeah. Yeah. Thanks for clarifying. Absolutely. And that is a great stat that you mentioned, Sam, the 40%. 40% of crime in the U.K. is down to fraud. That is huge. That is something we really, as a sector, given financial services contributes as much as it does to national GDP, it makes it really, really important that we do break the back of fraud, that we really do try and help reduce the incidents of fraud, and that fraud is not happening in the financial services sector. Hopefully, it happens elsewhere. But for now, it is. It is prevalent in financial services. It is a problem for us. It is an area we have to focus on. As many of you will know, probably a couple of years ago now, in response to the London Capital & Finance, what shall I call it? Review. The FCA had to retrain all of their staff on fraud. It is now finally coming to fruition. Finally, they are actually going to pay a lot of attention to fraud. So I think what does that mean for you and people on the webinar today? That means that you really need to understand what are you doing about fraud? What are your controls? What are your prevention techniques? How are you detecting fraud in the business? How do we know if that is coming up in our organization? Sam, do you want to go on to the next poll? Yeah, sure. So poll question number 2. Where do you see the potential for improvement or support through learning? If you would not mind participating in this poll. Maybe if some of you say unsure or none of the above, or actually, if you have just got thoughts as before, it would be really interesting if you do not mind just sharing something in the chat. Yeah. There are some comments coming through, Catherine. It is quite an interactive session today. It is quite good. I am just going to close the poll down now. We have got a good 70%, 80% people have voted. Bear with me and I will share the results. Does anything surprise you with that, Catherine? I think, again, this is something we have talked about before, but the fact that we have to keep doing learning and training on financial crime, and I know a lot of the training that has been done to date is all about money laundering. We need to broaden that. We need to absolutely broaden the training that we provide to our people around us on not just money laundering, but it has got to be the whole suite of financial crimes. We have got to focus and get the balance right across all the financial crimes, I think. Yes, money laundering is important, but I think it is really good that we can teach people about sanctions, we can teach people about the importance of anti-bribery and corruption. We can teach them about fraud. That is really important. A lot of frauds come up internally. It is staff in our own businesses that are committing fraud. It is not just external. I think we have to remember that as well. That is really important. And putting consumer needs first, yes. I am really not surprised that that is a very high up people's agenda in terms of training people. Yes. Someone makes a really good point. Yes, we have to get the balance right, but how do we make sure it is engaging and the training sticks in the mind? I think that is one of the most important things and one of the reasons why, we keep delivering regular, let us say, AML, sorry, I am picking on it, but AML training. We keep doing it, and we keep doing it, and yet the stats do not change. We have still got a problem with money laundering. We have still got a problem with fraud. Why is that? We have to change the way that we deliver the training. That is why things like just short, sharp interventions, short, sharp kind of training, that just few minutes rather than the sort of annual, what I call sheep dip through the mandatory learning. Yes, you have got to do that because you have got to evidence that you have trained people, but making it regular, doing awareness campaigns, putting posters up, if you are physically in the office, putting things up on people's screensavers, great ways of getting to people and just putting it front of mind. Often that is all that you need to do is, if it is front of somebody's mind, then, often it means that people remember it, and they will think about it a little bit more, and they might just ask the question: Does that look right? Does that feel right? That is a really important thing to do. In light of the Dear CEO letter in March, we have actually got a session where we are bringing a couple of financial crime experts in to discuss AML and that Dear CEO letter in a little bit more depth. So look out for that one, by the way. Looking at this slide, Catherine, I am thinking in light of the extensive focus on consumer needs and protections outlined in the notes above, could you provide some insights into the concept of a skilled person review? Specifically, what does it entail, and are there any exemptions applicable? Furthermore, considering the emphasis on Consumer Duty, throughout the points mentioned, would it be accurate to say that all of the elements on screen are largely revolved around fulfilling consumer obligations? Yeah. Great question. A skilled person review is something that is required by the FCA when they see that there are risks present in your business that they're concerned about, that they think are not being addressed adequately by the organization. What they do with a skilled person review is require the organization, under scrutiny, to then appoint a third party to come in and assess those risks as described by the FCA, and assess your level of compliance against those risks. At the end of it, then the FCA is provided with a report that says, "This is how you're complying currently, and therefore, these are the actions that you've either taken." Hopefully, you take them during the review, so that by the time, as with all good audit, by the time they actually come to write it up, the findings are, "Yes, we found that you had a deficiency in this area, but actually this has now been remediated, and therefore there's no sort of outstanding, or at least the residual risk is much reduced." It's something that you have to pay for. It's something that the FCA will require firms to do from time to time, and they do. They have a panel of firms, and I would always say, make sure that you look at that list of panel firms that the FCA has for skilled persons. They're published on their website. Also remember, that with a skilled person, if they've recently come in and done, I don't know, a health check for you, or they've come in and done some kind of review, or they're your auditor, they're going to be conflicted out of being a skilled person. Always try and keep, and as I say, assume the worst, but always try and keep one or two people on that skilled person panel available so that you do have someone that you can go to, and you roughly know who it is you're likely to go to, should the worst happen. Hopefully, you'll never need to. On your point, Sam, about is anybody exempt from them? The short answer to that is no. Anybody, any size firm, big or small, could be required to have a skilled person review. Often what you find with smaller organizations is that then the cost of the review, because they are not cheap, the cost of the review can often be prohibitive, and that means that the firm ends up having, let's call it conversations with the FCA about how they bring about closure to the issue. I would say in the context of all of this and what we've got on putting consumers' needs first, where has the FCA got to, particularly on Consumer Duty? We're not seeing skilled person reviews yet. But where are they getting to on Consumer Duty? I think what's most interesting for me on Consumer Duty is the fact that we're coming up to the deadline this year. We're coming up to the requirement to produce our board reports this year. We've got a lot of individuals who are champions for Consumer Duty, and they're now starting to say, "Okay, I get what my role was during the implementation program, but what is my role now in BAU, business as usual? What does that look like? What do I have to do? What do I do differently? What am I expected to do? How do I evidence that?" There's lots of questions coming out on that. What the FCA said they're going to do this year is they're going to do a lot of cross-firm work. They're going to do a number of market studies, so that they can understand within each sector, are they driving up standards? One example of that is they're going to look at unit-linked pensions and long-term savings, and they're going to be testing the transparency of charges across the value chains. They're going to be looking at how firms are assessing overall value, and then look at, okay, so in which case, what is unfair value and have some of those organizations identify what unfair value looks like. If you're in that unit-linked pensions long-term savings sector, you can expect the FCA to come out and ask you a few questions about what you've done in that space. We're also expecting the FCA to do a lot more work and many of you will already have seen the FCA's survey on vulnerability and customers exhibiting signs of vulnerability. I think we're going to see a lot more feedback on vulnerable customers, what the FCA expects us to be doing around vulnerable customers, and also then some good practice. They gave some great examples last, late autumn, I think it was, where the FCA was giving some really good examples where a lot of firms, and I know a few individuals who do this, but as a full-time day job, is their role is to look after and manage vulnerable customers for the organization. They're specialists. They're trained in having conversations with certain types of vulnerability. Obviously, it can be a big range of characteristics that could be classified as vulnerable. There's a lot of organizations who are doing more and more of this. I think from the individuals I know who do those roles, they said enormously rewarding. Obviously, you've got to be a firm of a certain size to actually be able to dedicate individuals to doing those sorts of things. We're also going to see FCA looking at things like savings rates. Are customers getting good deals on that? Are they being kept informed when rates are changing? We're going to see more, well, actually final rules now on mortgage, consumer credit, and overdraft rules. Those are going to come out. We're also going to see a lot more work around access to cash and what happens with closures of banks and bank branches. As you can tell from this slide, it was very difficult to trim this down, just to get something on the slide for you. There is huge amounts of work the FCA is doing on consumers and huge amounts of work that are happening this year. I think that's really the key takeaway. That's going to be their big focus this year. Expect to hear from the FCA. Remember, consumer, don't translate consumer to retail customers. Translate consumer to be a consumer, a user of financial services. Remember it in its broadest sense. Shall we go on and talk about wholesale markets? In wholesale markets, this is Sorry, Sam. No, because I was thinking about this, and I was wondering how might a new government approach these aspects differently to stimulate growth and innovation. I thought that would be quite an interesting thing to talk about. Specifically, Catherine, if you could provide some insights into potential strategies or policy shifts that could affect some of our community. Additionally, how do you envisage these changes impacting market perceptions and behaviors in the global wholesale markets? Absolutely. Yeah. Let's start with the biggest known unknown, if you like. There's this election coming up this year, and there's lots of commentary about what may or may not happen. Who knows? But one of the things I think I would really encourage you to do, if you haven't already, is read the Labour Party's strategy for financial services. I've got it on my desk here. You'll find that There we go. You'll find that online, just Google Labour Party strategy financial services. Have a read of it. It's fairly short, it's fairly light, but what you'll get from reading it is a sense of were the Labour Party to become a majority party in the U.K. at some point later this year, and many of you will have views about whether that will happen or not, I'm not going to comment. But, if you read that and read that strategy, you will get a good sense of what they're intending to do with this, if they get into power. Some of the headlines I take from what they say they're going to do are, Consumer Duty is going to be declared a big success and there's going to be, sorry, I'm paraphrasing, but there's going to be a whole bonfire of regulation on the back of it. Consumer Duty, outcome focus, great. That's been really good. We've all done a great job in the industry of implementing it. It's outcomes focus. We don't need chapters and chapters of rules in the FCA rule book. We can just scrap all of that hard work and cost of implementing all of those regulations. We're just going to get rid of all of it. That's part of their strategy. Reading between the lines, it looks like there's an inference that Consumer Duty could potentially get read across to non-retail customers. There's similar principles, but facing market counterparties, eligible customers, and so on. There's just an inference of that. They do not say it explicitly, but it looks like that's where they're going to go. While they say the FCA is independent of government, they also say that they're going to tell the FCA to do a few things, including Consumer Duty being one. The other thing they're going to tell them to do is to produce more guidance on diversity, equality, and inclusiveness. They do not say anything about what that looks like. They just say they're going to tell the FCA to do it. They're also going to tell the FCA to extend their scope to buy now, pay later markets. I do not think much of this is an enormous surprise, really. One thing that's interesting, we did touch on earlier, was AI. Somebody mentioned use of AI. The Labour Party say that they want to use AI in plugging the advice gap, and they want to tell the FCA to do a bit more work around that, sandboxes and the like. They also want to increase equity ownership, and I think for wholesale markets, that's rather interesting. Equity ownership in the U.K. is relatively low relative to other markets. Therefore, how can they increase equity ownership? Those of you old enough to remember the campaign Tell Sid, well, they're talking about doing something similar, not privatisations and things like that, but they are planning to do similar sort of campaigns to get people to invest in equities. That's rather interesting. The other flip side of equity investment, of course, is the digital assets market, and you will not be surprised to hear they're not silent about that. Actually, what they say is they want to see and encourage more tokenization of securities, which I think, in of itself, is also very interesting. They're also going to encourage more long-term fixed rate mortgages, a bit like the U.S. do, where you can have a much longer term, longer than 25 year fixed rate mortgage. There's quite a few things they're going to encourage. Central bank digital currencies as well, one of the other things they're saying they're going to do. Lots of things there that potentially, if we do get a change of government, that we might see coming in. Overlay that with what the FCA has already said they're doing, things like their reviews of the listing regime, publishing the proposals that they've published on new public offer and admission to trading, that regime as well. I think we're going to see a lot of changes coming in for the wholesale markets. You've probably also seen the headlines about their intention, the FCA's intention, that is, to introduce more options for how you pay for research, which I think has long been an FCA ambition. I do not know to what extent they really agreed with banning research anyway. I think we'll see that change, and that will be very interesting to see what happens. We'll probably also see a lot more focus coming up to the September deadline for UK EMIR. I think we'll see more focus from the FCA around derivatives reporting for those of you who are in scope of that aspect of the regulations. Lots of things going on in this space, and I think we will see a lot more activity from the FCA on this. One thing you might find very encouraging is that the FCA has committed to what the words they use is "modernize" their authorizations processes. That's something they're planning on doing this year. They've been trying to clear their backlogs, which they were doing last year. They had a bunch of consultants come in and help them do that. What they're trying to do go forward is then say, "Okay, how can we make our authorizations process much slicker, faster, more effective?" Because of course, we want more people to want to do business in the U.K. Getting them authorized is something that currently takes inordinate amounts of time. Any of you who've gone through a variation of permission will know how long it takes. They want to speed that up. I think that's a really good thing for them to do. Great. Shall we move on to our next slide, or do we have a poll before that? Yes. Shall we do the next poll? Then we can come on to the final slide on other commitments. Wonderful. Which, if the following, is the lowest on your priority list for 2024? Interesting results coming through, Catherine. Sam, as we were putting this poll together- It's not what I expected. I can see the results coming up, but I'll share them with you all shortly. I'll give it a few more seconds for a few more people to vote. Sam and I had a bit of a chat about that one. That's Alex, view of the audience. We were guessing what the results would be. Yeah, we did, didn't we? We're as interested as you are in voting on this. I bet you're all hanging on the edge of your seats waiting for the results. Maybe a few more votes, and then we can close it down and share. Okay, I'm going to close it down now. 5, 4, 3, 2, 1. Oh. That is interesting, isn't it? I did say. What are your thoughts, Catherine? Look, my take on this is shaping digital markets, great. But we're all going concerns, and we've all had technology and using technology in our businesses for many years. Actually, it's much easier said than done to suddenly say, "Oh, we're going to transform our technology landscape. We're suddenly going to digitize everything." It's really hard, and it takes an awful lot of investment. I can see why maybe that's a lower priority. This also says to me, operational resilience, right up there. That's what you're all focusing on, operational resilience and consumer outcomes. That's your sort of top two priorities. Shortly behind that is market abuse, and that I kind of think, yeah, I'm not surprised by that. Interesting, quite a lot of you then are potentially prioritizing ESG, and I guess that's SFDR and the new sustainability reporting obligations that are coming in, and perhaps you're having to spend a reasonable amount of time and focus and energy on those new regulations. That's super interesting. Thank you. Shall we just go on and look at the other commitments that the FCA's made? There's a lot of them, and a lot of other commitments, but really, things like, so market abuse, yes, they've got to start taking much more assertive action on that. We know if you joined the webinar last year, we know that the FCA hired a new team in to focus on fixed income commodities and currencies in the enforcement area of the FCA, so that they could try and secure some more market abuse prosecutions in those asset classes. Historically, the FCA's focused on equities, and they do still have a team dedicated to equity market abuse. They're also looking at market manipulation, not just insider dealing, front running. It's quite a diverse, a lot of things on that slide. I was just wondering how you foresee these priorities intertwining and influencing each other, Catherine. Could that be a potential for challenges, or are there opportunities that may arise from addressing these commitments concurrently? Oh, most definitely. Because, if you look at something like enabling consumers to help themselves and shaping digital markets, you look at those two together, well, actually, what you can do, and I keep saying it, I see the Consumer Duty as one of the most commercial pieces of regulation that we've got because it requires us to deepen our relationship with our customers. Brilliant. If you look at the customer journey and you say, "Okay, so why is it that customers are, I don't know, clicking through our app, and they get stuck at a certain point? There's a point where they disconnect, they leave something in their, call it the basket. They're going through the sales process with us, they're talking to a relationship manager, and then suddenly they drop out, and they go quiet on us. Or maybe they're an existing customer, and we keep seeing repeat instances of things coming up." Well, in digital markets and digitizing and changing our technology, that's all going to bring about some drivers for us, potentially, to say, "Look, actually, if you're looking at the customer journey and there are frictions in the process here, shouldn't we be looking at our technology and our technological solutions to try and bring about a better outcome for the customer?" You might also find that actually some customers, and I think we're seeing it more and more now, are saying, "Actually, I'm selecting the organization I want to deal with based on their publicly stated sustainable targets. How green an organization is this? Are they going to still send things through to me in glossy, huge, big brochures through the post, or actually are they going to do things electronically?" All of this, for us, saves us costs because who wants the printing costs and the postage costs? It's much cheaper to be able to put things up online, but how do you do that in a way where you're not excluding anybody? There's an awful lot in all of this, and as you can probably tell, we could talk about this for hours. And actually, I think, Sam, you've got something coming up soon where we'll go into all of this in a lot more detail, next month. Yeah. We took the decision to consolidate some of our events and hold slightly larger seminars, like four a year perhaps. But our upcoming seminar in May, on the 16th, we've actually brought a number of experts together, to cover off, the keynote from the regulator, on the update for the business plan and talk about Consumer Duty and what that looks like now, where we're at with it, where we're struggling, data, innovation, and learning. So we're bringing all these sessions together as a morning session, which I think would be quite beneficial for most people, with people like PIMFA and Shoosmiths and Linklaters and Keystone Law. We've got lots of really expert people that have got a lot of experience that they're bringing to the table to talk about some best practice. And obviously, Catherine, you'll be there yourself, so we can tap into you once again. And I think it's great to have these kinds of sessions, and to get the feedback on the webinars, et cetera, as to where people are struggling, so that we can provide that extra layer of support for them. But yeah, so that's looking really good. I think we've almost fully oversubscribed, for it in fact, so very excited about that session coming up. Are there any other strategies or approaches, before we move into our Q&A, that you think would be effective in navigating all of these changes and ensuring positive outcomes for all the stakeholders involved? Is there any last bit of advice that you would give people, something that resonates with you? There is one thing, actually, just picking up on a comment that somebody has made about taking assertive action on market abuse and what my views on enforcement and market abuse in the next 12 months are. I heard the head of the market abuse function of the FCA saying, only a few weeks ago, they have got a couple of really big cases going through the courts at the moment. He, excited, I think is the right word. He seemed very enthused about the potential outcome of that and the fact that they would have something to say soon. That would be really good. That would be really good if they do, because they are long overdue, some really big cases, and they have had a lot in the enforcement pipeline. It would just be good to see some enforcement cases coming out. I think that would be, in the nicest sense, I think it just shows that they are exercising their powers in the right way. In market abuse, it is really important that they do that. Same with CASS. Both of those are enforcement-led regimes. It would be really good to see that coming out later this year. We should see more enforcement action from the FCA as they start clearing up backlogs and catching up. They are investing in their staff, so I think the other optimistic outlook for the rest of this year is that they will invest in their people, they will train them, and they will get them up to speed. I think that is really important. I think a number of you have probably spoken to the FCA and sort of felt a bit disheartened because, they have sort of juniorized a lot of their teams lately. It is really important to see that they do step up a bit more. Thank you, Catherine. As we kind of come towards the back part or the end of our webinar with you today, I just wanted to remind you all that these webinars are sponsored and hosted by Skillcast. Skillcast are committed to supporting compliance leaders and professionals along their journey, via their FCA course library, which comprises over 60 e-learning modules, and covers a wide spectrum of regulatory topics. It stands ready to equip your organization with the knowledge and tools needed for success. With specific versions for banking, investment, mortgages, and a comprehensive SM&CR training course, Skillcast ensures that your compliance training is tailored to meet the needs of your industry. Oh, that came off slick, didn't it? To explore our LMS systems and courses and our RegTech tools, please encourage you to take advantage of the free trials on our website. Let's wrap up today's session by extending a sincere gratitude to all of you for joining us. I would also like to deeply thank Catherine for sharing her expertise with us all once again. Skillcast Connect is our community, which is designed to bring all of our compliance professionals and experts together, so we can support each other as we strive for compliance excellence. By joining our community, you get priority access to invaluable insights and resources within a friendly and supportive environment. Please join using the QR code on screen. I would just like to remind you that we will be sharing the slides from today's session in our follow-up, so keep your eyes peeled for that. If there are any other questions that you would like to ask or you would just like access to our expert speakers, so you can ask further questions, please don't hesitate to reach out to me directly. Once again, thank you all for your time and participation, and we will see you at the next webinar.