100-day breathing space to increase agility and improve Brexit readiness

Nicola Cowburn
Nicola Cowburn
July 7, 2016


While Brexit has the lion’s share of thought-space currently, much of the abundant commentary is filled with speculative evaluations of possible outcomes, and is riddled with ‘ifs’, ‘buts’ and ‘maybes’. But, uncertainty is an inherent characteristic of financial services.

Fact #1: at this point no-one knows what ‘out’ really means. According to financial services regulatory expert Lisa Cawley (Partner, Kirkland & Ellis), there are six possibly alternative courses of action. The exact course that is negotiated for the UK’s future won’t be decided upon until a new Prime Minister is appointed, in October.

Fact #2: For the next 100-or-so days, there is little that financial services firms can do to make positive plans for building an operating framework that is fit for the Brexit future. Industry analysts are urging the C-suite to avoid naval-gazing, and use those 100 days productively to prepare for the multitude of scenarios that lie ahead, by increasing flexibility and agility. We find ourselves in an unpredictable situation, where the devil is not in the detail. In fact, it is impossible to know the detail of what lies ahead, so the best course of action at this point is to adapt processes, and leverage technology, to inject flexibility and agility into your infrastructure.

Top of the list to tackle is the C-suite’s #1 concern – legal and compliance issues. While much of the UK’s current financial regulation comes from EU legislation, this will remain applicable at least until Brexit negotiations are complete. This won’t be any time soon, and is a matter for government, not the regulator. In the meantime, firms will be required to continue with implementation plans for upcoming legislation – not least MIFID II. “Consumers’ rights and protections, including any derived from EU legislation, are unaffected by the result of the referendum and will remain unchanged unless and until the government changes the applicable legislation,” the FCA said.

Tackle low-hanging fruit first – the areas that can easily be resolved within 100 days in a cost-effective way. Ensuring compliant record-keeping of all digital activity – online, social and mobile – is a perfect example of this. And being a MIFID II requirement, it ranks high on the agenda for every financial services firm.

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Read more

Part 1: Communicate with your customers, as though your life depended on it

Part 3: Scrutinize current systems and take action to cut the cost of compliance

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