Speech by Andrew Proctor, Director – Enforcement, FSA

FSA – Training & Competence Conference Senior Management Responsibilities - Getting It Wrong – Potential Implications

Speech given on December 15, 2004.

His Introduction follows:

I. Preamble
Most of what I have to say will be broadly familiar to you, and I hope that many of you will have heard me speak before about some of the themes I will touch on this afternoon. Other speakers will give you enough of the detail around the T&C regime and our expectations for me to safely pass over that. There are two things I would like to emphasise.

II. Agenda
Firstly, I would like to assure you of the importance that we place on a good T&C regime when we come to make key enforcement decisions. There are two aspects to that: the decision to take a case into enforcement at all, and what we do once we have received that case into enforcement. Both of these decisions involve fundamental considerations of the quality of T&C within firms in many cases.

Secondly, I would like to give you some material to take back and use in debates and discussions within your firms when you reach the difficult part of the year when people are asking for budgets to allocate to T&C. I would like to give you some arguments to put to senior management in support of adequate investment in T&C. To do that, I need to give you some information that will enable you to persuade senior management within your firm that it is in their best interest that they make that investment. David has described in some detail our expectations of senior management in the context of the T&C regime and our handbook, and the wider legal obligations that most firms and companies have.

See full Speech.