A New Approach To Retail Customer Protection
The FSA's 2011/12 Business Plan signals a new regulatory approach to retail customer protection. Past approaches based on fair disclosure, the regulation of sales processes and regulatory reaction after the event have failed to prevent high volumes of customer detriment. The FSA's new approach will be much more about identifying emerging and potential risks than waiting until those risks have crystallised. Whilst the FSA accept that further work is required both to determine the details of the new approach and to ensure its effective implementation, what is clear is that the focus will be much more product specific. In this context it is worth noting the following emerging product risks that have been identified by the FSA in their Retail Conduct Risk Outlook 2011:
- Traded Life Policy Investments;
- Exchange Traded Funds;
- Self Invested Personal Pensions;
- Unregulated Collective Investment Schemes.