Alan Hughes


Alan Hughes: Meeting FCA expectations of principal firms

These companies should ensure their systems and controls address recent issues found by the regulator Last month, the FCA published its findings into a review of how principal firms in the investment management sector understood and complied with their responsibilities in respect of their authorised representatives. The firms covered a diverse range of regulated businesses, […]


Alan Hughes: FCA is not on a mission to end DB transfers

It is not its intention that access to high-quality transfer advice and products becomes too difficult, but more detailed guidance is needed On 22 March, the FCA wrote to the chief executives of pension providers with the conclusions from its latest work on the defined benefit to defined contribution transfer market. The thrust of the […]


Alan Hughes: FCA finally grasps the nettle on phoenixing

In November, the FCA published its Approach to Authorisation document, containing feedback on its December 2017 consultation paper on the same topic. It is a very useful and detailed account of how the regulator determines applications for authorisation by firms and for approval by individuals, as well as how the new senior managers regime may […]


Alan Hughes: The most important lesson from Berkeley Burke case

FCA must give greater consideration to where detailed rules would result in more effective regulation and better protection Last month saw Sipp provider Berkeley Burke lose its High Court appeal against the Financial Ombudsman Service. The appeal followed the Ombudsman’s decision against Berkeley Burke for failing to carry out adequate due diligence on an unregulated […]


Alan Hughes: FCA’s new duty of care rules are a waste of time

The FCA has released some interesting papers recently and generally seems to be demonstrating a more interventionist approach – or, at least, earlier intervention. For instance, it has decided it needs to impose more detailed regulation and governance on P2P platforms, as the market is putting consumers at risk of serious detriment. It is also […]


Alan Hughes: Is your DFM putting you at risk?

The ‘agent as client’ model has come under the spotlight again, with concerns raised that advisers are being exposed to unexpected regulatory risk The issue of adviser/discretionary fund manager relationships has raised its head again – in particular, the “agent as client” model. Despite the best efforts of some in the industry, confusion remains around […]

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Alan Hughes: Did FCA authorisation process fail British Steel members?

Questions have been raised as to whether the regulator should have spotted warning signs at the key firms involved earlier. Recent weeks have seen depressingly familiar headlines being bandied about, as the British Steel saga continues to play out. Hearing the phrase “pensions misselling scandal” being regularly used shows that, despite the progress made on […]