4. What's next? Preparing for the regulatory look-back
The FCA will inevitably conduct a look-back in six or so months' time to assess how firms operated and managed during this period.
It is crucial that business decisions made now stand the test of time and prove to be robust when the regulator comes knocking.
Those decisions which have a direct client impact will be a key focus. The FCA announced various areas where they are providing specific flexibility, including the 10% asset depreciation reporting due to market volatility.
But this is not a free pass. Any decisions made by firms regarding how their services and products are offered should not undermine consumer protection.
The senior manager accountable for that decision should have oversight of the whole process through to the point of communication with clients.
Wealth managers should also view the current situation as a form of stress-testing on steroids, and an opportunity to step up.
Firm-wide processes and procedures are under the spotlight as we adapt to the new norm of remote working; allowing us to assess what works and what doesn't.
BCP plans no longer sit on the shelf for a rainy day but should be updated to reflect a new reality. As the adage goes, never waste a crisis. The day in the life of a senior manager just got a whole lot more complicated.