The financial regulators in the UK have been quick to articulate how their expectations of banks and other regulated firms will reflect the changed circumstances the economy finds itself in. There is latitude available in a number of areas, to ensure firms can continue to operate despite remote working and other constraints.
However there are also some important areas which require very careful planning and execution - three examples: maintaining appropriate controls and records of calls in dispersed call centres (with operators working at home); re-allocating Senior Management roles for the crisis; and maintaining operational resilience, despite the remote working model affecting most staff.
We expect all firms to have contingency plans to deal with major events and that the plans have been tested ...
... Firms should take all reasonable steps to meet the regulatory obligations which are in place to protect their consumers and maintain market integrity. For example, if a firm has to close a call centre – requiring staff to work from other locations (including their homes) – the firm should establish appropriate systems and controls to ensure it maintains appropriate records, including call recordings if required.
We will continue proactively discussing with firms and trade associations the issues they are facing, and we will be continuing our active dialogue with them in the coming days ...
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