Well, the first quarter was one of the busiest I’ve had since I started doing financial services training in 1996. The second quarter seems certain to have been one of the quietest.
With the end of the pandemic, everyone seemed to be saying that they wanted to attend face-to-face courses so as to meet people during the breaks and more intimately during course discussions. Something is not working in that area either. July seems certain to mark the first pure face-to-face public course I have run since early 2020. I have done one in-house face-to-face and two hybrids where about half the participants joined remotely.
What is going on?
One excuse or reason for the huge number of dates that have come into my diary and then been removed since the start of the year is the July 31 deadline for the introduction of the Financial Conduct Authority’s Consumer Duty. As my friendly IFA (carefully chosen because he is not a client of mine!) pointed out, the Duty could have been invented for me. Customer-facing compliance is my thing. The fact that I think that the FCA has gone about the problem the wrong way round – it should have sorted out its supervision and enforcement of the existing rules before it added a layer of extra one and just extended the PROD rulebook across the regulatory framework with an extra section on “customer support” – is probably irrelevant. I have done my fair share of consumer duty courses along with product governance ones.
Did the regulator understand that, by creating a big project and insisting on some meaningless plans and data, it was actually stopping firms from learning about what they were supposed to be doing on a daily basis? The media suggest that the regulator has shifted a large number of staff members to cope with 31 July. So, even by doing that, it must have realised how much disruption it was causing – at the very least to itself. In other words, by creating an event, with vast amounts of data, the regulator has effectively short-changed its own objectives.
That is not entirely fair. The customer support obligation which is new to the rulebook although it follows pretty obviously from the existing Principle 6 (treating customers fairly) has concentrated some minds on call-waiting times. That is not a bad thing. Although the value measure bits of the Consumer Duty are actually inherently impossible to comply with (how can you measure value for money?), they may be calling time finally on some of our more unacceptable practices (price-walking or treating existing customers far worse than new ones is an example). The point is that creating a project event is unnecessary for this purpose and is pulling people away at both the regulator and regulated firms from what they are supposed to be doing.
So, where does that leave learning? People have not worked out whether they want to go back to face-to-face training. There are actually some significant advantages to doing case-based learning through Zoom although not other platforms. (Don’t get me started on the awfulness of Teams!) There is nothing wrong with a mixture although hybrid events are very tough on the trainer. Maintaining a point of focus is the obvious issue. Perhaps, the Consumer Duty issue will sort itself out after July.
On a more positive note, the last couple of days, I have been running an in-house complaints course. One of the very good people attending was the learning and development manager. People who arrange courses really should attend them to find out whether they are any good.
#thecompliancefactory #compliance #training