The latest FCA Board minutes provide the usual mix of tantalising hints of interesting initiatives and portents of future troubles.

Strategic Workforce Planning Review (2.2)

This sounds like quite a grand idea, though the underlying evidence it can draw on will be much less than the NHS equivalent.

When the regulator has previously attempted planning along these lines, its ambition has either been narrower in scope (eg the Supervision Enhancement Programme of 2008/10) or had a shorter horizon (eg the three-year resource-planning of 2010/12). None of these initiatives been especially successful or long lasting and the causes of their relative failure are numerous. But it hasn’t helped that the corporate centre hasn’t had sufficient strength to act as an impartial arbiter between the duelling barons (ExCo members), or that the regulator’s HR function (sometimes for good reasons) has never been given the authority needed to implement the resulting plans.

Hopefully, these weaknesses have been rectified as proper, long term “workforce” planning has always been a damaging gap in the regulator’s toolkit.

National Audit Office (NAO) review of effectiveness (3.1.i)

The closest comparator to this forthcoming report is the NAO-led 2008 Hampton Review of the FSA’s “Effective Supervision & Enforcement”, which was thorough in its approach and, even post Northern Rock, gave the FSA a pretty good write-up. More recently, the NAO’s 2014 Report on the FCA took place only a year after the FCA’s creation and so was essentially limited to a judgement on its approach before this had suffered contact with reality,

There are several reasons why the 2008 FSA survived what could easily, given the unfolding financial crisis, have been an extraordinarily painful set of judgements. Perhaps the biggest reason is that, for all its flaws and stretched resources, the FSA was relatively well funded and more sophisticated compared to other UK regulators, perhaps due to its independent fee-raising powers, relative freedom from Whitehall, and the complexity and international nature of financial services.

I suspect that the FCA’s reputation is weaker now than the FSA’s was in 2008

Clearly some of these factors persist, but I suspect that, despite Northern Rock, the FCA’s reputation is weaker now than the FSA’s was in 2008, eroded as it has been by a steady drip of regulator failures, such as London Capital & Finance and pension freedoms, that lack the global aspects of the great financial crisis. In addition, the latest review will partly focus on crypto and artificial intelligence (AI), where, in contrast to traditional financial services, the FCA has little inherent advantage in expertise.

Likewise, data strategy and evaluation of outcomes (effectiveness) – obvious targets for the review – are areas where the NAO will be able to bring to bear their comparative experience elsewhere across government. And, completing this particular circle, crypto and AI are also two of the areas which you would expect to feature in a strategic workforce plan, so we should also expect to see this within the scope.

Diversity & Inclusion Consultation Paper (3.1.ii):

This was originally scheduled for Q3 last year and is now due to come to the Board in June or July (last month or this), and it feels like the FCA and PRA have got themselves into a tight corner on this. We shouldn’t therefore be surprised if the result dials back the rhetoric of the original discussion paper.

A decade ago, the FSA looked at some of the ideas this contained but concluded the evidence base to justify new regulation wasn’t strong enough. So, unless this situation has changed markedly, the cost benefit analysis for new rules will be a challenge.

Notable omissions

Nothing on the cost-of-living crisis or the Consumer Duty!