Merry Christmas 

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In a little over 24 hours time, we'll be shutting our office for the Christmas break, reopening on the 3rd January.  This has been a full-on year in business-development and compliance terms, and regardless of how individuals may feel about Christmas, we are all looking forwards to the break.  I hope that all our Members, clients and professional colleagues have a very relaxing and special time which will set you up for an enterprising 2017.

At ValidPath, one of our little traditions has been to produce a review of the past twelve months, from a regulatory perspective.  This time around, the reference source which we use for the purpose is late coming, and so I will simply direct our Members attention to the historical account which we have accumulated over many years, and which we call 'Best Practice Lessons'.

I do not want to anticipate what that analysis may tell us - but I did want to pick out one key theme which has come to the fore over the last 12 months, if not over several years.  This is the strategically critical concept of 'joined-upness', and the reason I am mentioning it is because (a) the lack of joined-upness appears to be to be an absolutely key weakness to any enterprise, and (b) the FCA does not demonstrate this quality in the way it operates.

Joined-upness is rather more than having plenty of hyperlinks within one's electronic documentation - and the unwary reader can venture into the FCA Handbook and never escape, if they choose to follow those misleading blue links.  Joined-upness requires individuals who will take a strategic overview of what is happening, and take ownership for it.  The underlying brevity of tenure in management at the FCA pretty much makes this impossible in practice - continuity is an important element of joined-upness.  What you get otherwise, is a kind of switchback of changes which, cumulatively, produce unintended outcomes.

Joined-upness also requires a consistency of belief.  What we actually get, more often than not, is a kind of pragmatism - we do the stuff that works.  But just because something works in situation 'A' doesn't mean that it's likely to work in situation 'B' (or 'Z').  And so we end up with a continually morphing model that almost inevitably throws up other unintended consequences as it goes along.  A consistency of belief doesn't happen in a vacuum, because it requires a consistency of believers, and that's precisely what you don't get in organisations like the FCA.  Joined-upness also requires a consistency of culture.  Within the regulatory hierarchy in the UK, one finds the FOS culture which appears fundamentally antithetical to the FCA culture, with the poor IFA caught as piggie-in-the-middle.

Joined-upness.  The lack of it is, in my humble opinion, one of the biggest risks we now face as a profession.  We cannot count on the Regulator to exhibit it, and we have little evidence that, historically, it has.  This makes it all the more important that we know where we're going.  This means having a very clear view of the following strategic components:

  • we should know exactly what kinds of outcome we are creating for our clients
  • we should have in place exactly the right kinds of tools to achieve those outcomes
  • we should be able to clearly articulate what those outcomes should look like - to the client - prior to taking action
  • we should be able to demonstrate that these outcomes have resulted from our service and advice (which means good compliance)
  • we should have in place the requisite processes to deliver these outcomes

Merry Christmas, everyone!