Conduct Risk and Financial Stability [14]

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Bullet points include: FCA Theme. Analysis. 1. Technological change may outstrip firm’s investment etc. IT involves ‘systems’ and experience indicates these can introduce vulnerabilities, although may not be the same systemic risk of the Financial Crisis? 2. Poor culture and control: threatens market integrity. Market integrity requires trust between market participants (and between firms and their customers). 3. Firms may act against (existing) customers’ best interests. Customer trust strengthened when firms play “fair”. 4. Pensions etc. may deliver poor consumer outcomes. Is the pensions system ‘systemic’? 5. Poor culture and practice in consumer credit affordability. A specific example of 3? 6. Range of issues relating to unfair contract terms given sharper focus. A relatively time specific issue? 7. Firms’ systems and controls important in preventing financial crime. Crime diminishes trust in financial system (and in social fabric more generally)

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