The FCA, webform design and TCF 

Completing our half-yearly (now augmented to quarterly) FCA RMAR is always a moment uncannily akin to the one where you stop beating your head against a brick wall.  Just momentarily, the cessation of physical and mental discomfort is such a profound thing that, briefly, one experiences a pang of gratitude that the FCA should have made such a thing possible. 

For the structure and extent of the RMAR is always morphing and expanding.  There is never any advance notice to prepare one for the significant additional investment of time that will be required when completing the latest version, but perhaps that is a calculated stance, bearing in mind the potential fragilities of the human mind.  A little while back, the FCA's team of web-developers added in a whole new section to RMA-G, entitled 'Professional Standards Data'.  For each individual CF30 Adviser, it requires twelve columns of data - which for (our) forty-nine Advisers requires five hundred and eighty-eight separate manual data entries.  See!  I can do maths.

The webform is almost unnavigable as a result.  Twelve columns require the widest of computer monitors, if one is not to endure the purgatory of continually scrolling left and right, to check what on earth it was that you just entered.  Because the manual entry is so tedious, the Gabriel system continually times out whilst you are working on the form, requiring a great deal of re-keying.  Printing the form out in draft mode is a problem, so it is actually quite a challenge to manually prepare for the magic moment of data-entry.  In the real world, no responsible systems developer would ever design something intentionally in this way.

And here's the crazy, crazy thing:  most of the information the FCA is asking already has.  It knows who the CF30 Advisers are - because the data is already on the Register.  It already has dates of birth, NI Numbers, Passport Numbers, Nationalities.  It is already supplied with SPS accreditation data for each Adviser (we know this because it is quick to spot delays in updating the SPS, so it has direct reporting from accreditation bodies).  In fact, as I review the content required by this form, I can see only two possible items that we might have available to us, which the FCA does not already have - which means that 83% of all that laborious data-entry is simply redundant, superfluous to requirements.

It's worth reflecting on this.  Can you imagine providing an annual review service for clients where you required them, on every occasion, to fill in an entirely blank FactFind from scratch?  What if you required them to do this, say, six-monthly, or quarterly?  Each time, a blank form, refreshingly uncontaminated by any legacy data.  I am pretty sure your clients would very quickly tell you where to go, and in not very polite terms.  It would not require supranaturally-enhanced sensitivities to regard such an approach as demeaning, wasteful, inhumane.  As I peruse the FCA's own twelve principles of TCF, I can see at least five of these which would be breached by such an approach.

It is difficult to understand why the sauce that is good for the goose is not also good for the gander, unless, from a regulatory perspective, the status of financial intermediaries is regarded as a far lowlier thing than the status of 'consumers'.  After all, consumers do at least have the right of not consuming our services, whereas the nature of regulation implies a negation of similar rights for intermediaries.  If regulation is to be a viable framework for financial services intermediation, it does need to demonstrate similar attributes to those which are necessarily attached to the whole business of TCF:  so far there is little sign of progress in that direction.

Kevin Moss, 08/11/2017