The summer lull is upon us, then, and many of you will exhibit tried and true migratory patterns as you head for a magical place known only to the top socioeconomic decile of the population as The Corn Wall. Exactly what it is about the corn, or the wall, that leads so many urban-dwellers to flock there, pretend they’re having a nice time and then flock back to complain to their friends about how many others in the flock were there, is lost to science, but here at the Update we’re led to believe it has something to do with fish and chips.
Anyway, the one thing you don’t want when you’re about to start flocking off to The Corn Wall is a shot across your wings from the regulator, but that’s exactly what the platform industry got the other day with a Dear CEO letter. For the uninitiated, Dear CEO letters are the regulator’s version of Postman’s Knock; you’re busy doing whatever – perhaps packing matcha powder for your trip to The Corn Wall in case there isn’t any there despite the fact there definitely will be – and then this drops through your letterbox with no warning and absolutely flocks up your day.
These letters are much less formal than consultations or policy statements; they’re a sort of official version of the things that folk say the regulator is interested in; if they’ve done a Dear CEO about it then you’re on notice that they really are.
This time the Dear CEO-bullet was about the stability of platforms, and also a wee warning about making sure that the regulator is kept up to date with any naughtiness and devilment that may have been occurring in said businesses.
Much of what’s behind the letter comes from the meme stock insanity around Gamestop and whatnot, and so concerns stockbroking D2C platforms more than boring old buy-and-hold advised ones. Nonetheless, paragraphs like this clearly apply across the board:
Policy Statement PS21/3 sets out our final rules and guidance on building operational resilience with which firms should be familiar. The rules and guidance, which come into force on 31 March 2022, set out that applicable firms must identify their important business services for the purposes of operational resilience. Firms must set impact tolerances at the point at which disruption would cause intolerable harm to consumers or risk to market integrity. Firms must map the resources that support their important business services and test their ability to remain within their impact tolerances through a range of severe but plausible events. Firms must have communication strategies in place to respond quickly and effectively to operational disruptions. Firms should compile, and regularly review, a self-assessment document which shows how they meet our operational resilience requirements. The document should be made available to us on request.
That’s 143 words that signal a whole heap of work for platforms to do. As of next March, this kind of mapping and risk management needs to be in place – it all sounds very grungey and the sort of thing that we would expect critical infrastructure to do: which is what we all say platforms are.
If you’re an advice firm of any size, we think the results of all this work will form an excellent and useful part of the due diligence you should carry out on the operational capabilities of any platform you already use or are considering using. Everyone does well when things are fine. The real test is what happens when the guano strikes the air-cooling mechanism.
A final thought on this – we launched a paper last week with the fine girls and boys at Seccl about what’s involved for advisers and discretionary firms thinking about operating their own platform. This is a good example of what we mean when we say this comes with new responsibilities – the platform operator is on the hook for all of this. We don’t doubt for a minute that the underlying providers of these private label platforms will be active in helping evidence their meeting of the requirements, but it’s the job of the operator to ensure everything is tickety-boo.
So there we go. Enjoy the break.
A JOKE ABOUT SEASIDE LINKS GOLF OR SOMETHING, I’M TOO TIRED TO THINK IT UP
- Yet not too tired to tell you about #HomeGames this week, which has the brilliant Ray Tubman, CEO of Finocomp which was recently acquired by Bravura, all over it. Ray is a) Australian, b) very funny, c) incredibly knowledgeable about how the UK platform market got where it is and d) a strong believer that it can be rewired for the better. We’ll talk about all that, but we won’t talk about a certain conference I may have met him at in the Hunter Valley winelands in 2014. This is the last #HomeGames for a month or so as we too flock off for a bit, so come along and enjoy. 12.30pm as ever or later on the YouTubes.
- I notice that SJP is really hurting as a result of the SOLID BURNS advisers are delivering regularly on social media. Great work guys.
- And sad news that Slipknot’s ex-drummer Joey Jordison has died at 46 years old. A natural music choice would be to put something from Iowa on, but to be honest I never liked Slipknot all that much until the most recent record and Joey didn’t play on that one. But he was one of the great metal drummers, and to prove it here he is improving Metallica immeasurably, as indeed any competent drummer might. I realise drumcam footage isn’t everyone’s cup of tea, but that’s your problem not mine.
See you next week, assuming you’re not queueing for fish suppers in Padstein.