Hugh Savill, Director of Regulation, ABINot many people know that Bob Marley started off in life with a small insurance business in Trenchtown Jamaica, where Bunny Wailer was Chief Actuary.
No? Well, bear with me.
Looked at forensically, Sheriff John Brown’s death is a murky business. We have a confession, a history of bad blood, a weak plea of self-defence. And, to compound matters, not much of an alibi for the murder of the deputy.
What about our lawmen at the FCA? "Shoot first, ask questions later," Sheriff Martin Wheatley famously said as he rode into town on his bony white horse. At the time this created quite a stir, and much head shaking in the saloon.
'A thoughtful regulator'
But what has he actually done? In the main, the FCA has been a thoughtful regulator. Sheriff Wheatley has only resorted to his enforcement gun when provoked. FCA thematic reviews follow a measured pattern, with an initial report setting out the problems the FCA sees with a market, usually inviting the industry to “reflect.” This is important: it is not an invitation to do nothing; it is an invitation to the industry to find its own solutions to the problems.
Imagine there is a brawl in the saloon, things get out of hand, and some furniture gets smashed (likewise the occupants). When the Sheriff walks over the street and invites you to reflect, it is just not wise to carry on as before – even if you yourself have not yet spent a night in his lock-up.
So it is best for financial services providers to read the thematic reviews carefully. The FCA expects all participants in the chain between product development and end user to play their role in ensuring a good consumer outcome.
To be sure, not everything has gone perfectly:
- some of the FCA’s press releases have been more outspoken than warranted by the facts – or is the lurid prose of the town recorder at fault?
- their information requests can be burdensome and are not always thought through – poor likenesses on the “Wanted” notices, etc;
- there is room for improvement in the organisation of some thematic reviews.
This is a new regulator, still finding its feet, and the townsfolk should bide their time in patience.
Bob Marley in Concert, Zurich, 1980 - photo by Ueli Frey.So why shoot the sheriff? We all know what happens next. Lawless gunmen in dusters ride into town, honest citizens are strung up from a dead tree, and only the vultures and the undertaker are truly happy.
Bob’s excuse was that reflexes got the better of him. Impressive marksmanship, through all the gun smoke and ganja haze.
But so it was that Marley Insurance was closed down, reggae took off worldwide, and now we will never know whether insurers would ever have fallen for dreadlocks.
Hugh Savill is Director of Regulation at the Association of British Insurers (ABI).