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Time to take control of the cost of compliance

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By Patrick Oldoni, Head of UK Practice, Severn Consultancy UK Limited

Most people in the insurance industry know that the regulators are going to make their lives very difficult indeed in the years to come. With the birth of the FCA and the PRA in 2013, there is a growing sense that these new UK authorities are going to shine their lights into every dark corner of the market, while on the European front, preparations for Solvency II will rumble on.image007a

The days of simply jogging along maintaining compliance between ARROW visits have long gone. Both regular submissions and ad hoc requests for information from the FSA, Lloyds and the other regulators already come thick and fast, reaching into every department and function. However, the FSA has made it abundantly clear that the FCA and the PRA are going to take a more interactive approach. We can expect them to be even more demanding, continuously and doggedly probing every aspect of insurance companies’ conduct and financial prudence in their quest for transparency and protection of the policyholder.

This will reinforce the imperative for absolute consistency when responding to information requests from the regulators. It will also demand a much more streamlined and coordinated approach to the way insurance companies manage both their internal communication and external interaction with the regulators. Most firms currently deploy a reactive, de-centralised approach to respond to regulators’ data requests, which introduces a genuine danger when responses to regulators are run through silos, rather than being properly managed and coordinated across the company.

There is no doubt that the coming regulatory environment is going to be highly disruptive and it would be simplistic to imagine that these new regulators will be concerned about the effect they have on the day-to-day running of the companies they supervise. They will not be worrying about the cost of the lost business opportunities they may cause, nor the fact that they might consume senior and valuable people’s time, keeping them away from essential tasks that have to be delayed or carried out by others. And they will certainly not lose sleep over the additional demands they place on the risk and compliance, finance, and actuarial departments – or indeed anyone else in the organisation.

At a recent breakfast seminar hosted by Severn Consulting exploring the management of regulation within the insurance industry, one of the biggest concerns voiced by delegates was the future cost of compliance and dealing with regulators’ demands. It’s hard to predict. But one thing is certain: when you take into account the total opportunity cost, disruption, short-term diversion of resources and consumption of management time, that could very well add up to a very big number indeed.
The killer problem though in an industry that is based entirely around the idea of quantifying risk, is the uncertainty about the future costs of dealing with regulators in this much tougher environment. With wafer thin margins in so many market sectors, any unknowns when it comes to the future cost of compliance could cause a problem.

Perhaps even more alarming is that many companies have yet to work out how they are going to respond to this challenge.
As things stand, most insurers run their regulation management through their risk and compliance offices. They pass on requests for information from the regulators to the relevant people or departments and then channel back the responses. The difficulty is that in most cases this approach is already creaking under the pressure from the regulator and the sheer volume and complexity of their requests.
This is unsatisfactory for many reasons, not least of which because it’s prone to error and few people have a complete picture of all the status of all information requests. Indeed, this tactical approach could well blow up entirely when the FCA and the PRA get into their stride. The risks of providing inaccurate, or even inconsistent data, the regulators getting heavy and matters escalating are considerable. And nobody in the insurance industry can afford to take any kind of gamble with their reputation.

But even leaving aside the growing problem of risk that this ad hoc approach to regulation management will carry in the post FSA era, it is also highly inefficient and costly. Duplication, misunderstanding about what’s needed and when, delays and black holes are almost inevitable as the demands for information increase. This all adds to the overall cost of compliance and regulation management and makes it even more unpredictable.

So how do you take control of the costs of regulation? The obvious answer is to manage the process properly through a centralised Regulatory Office (RO) providing a single point of contact for all regulators and internal departments. The exact scope and scale of the RO should be decided by the scope and scale of the company itself, but using simple project management techniques, they would maintain a complete understanding of the status of all information requests across the firm. This will also enable them to anticipate problems, allocate resources appropriately, avoid duplication and minimise unplanned disruption to other business as usual activities, and lost opportunity costs.

The RO will also be in a good position to direct and co-ordinate the implementation of any structural or operational changes that may be required by future, as yet unknown, regulatory demands. Indeed, horizon scanning and the practical analysis of future regulatory trends should be a central function of the RO.

The RO will not only introduce rigour, transparency and control to the process and costs of regulation management, it will also be able to achieve more subtle benefits through its close working relationship with the regulators. If it does this well, it will be able to achieve discreet flexibility when it is needed most. For example, it may be able to influence the timing of some ad hoc information requests so that less disruption is caused. For example, the finance department would prefer not to be dealing with a sudden and detailed information request when they are busy with the year end. Equally, the IT department would feel the same if it were racing to complete a major change management project.

All these subtle compromises, earned through a proper but close working relationship with the regulators, would deliver additional operational benefits. Such a relationship would be virtually impossible under a decentralised, ad hoc regulation management system. Indeed the chances of not being able to satisfy the regulators under a diversified approach, resulting at the very least in more scrutiny and escalating demands for substantial and detailed information at short notice, will surely increase along with all the attendant costs.

The arguments in favour of a centralised regulatory management operation are compelling from every angle. The risk of non-compliance and reputational damage in a much more intensive regulatory environment, either through error or misunderstanding, will be substantially reduced. Costs of regulatory management can be controlled and minimised. Finally, the RO is a scalable concept, with systems, protocols and resources that can be expanded and adapted to meet any challenge or demand that any regulator might throw at it.
No one can predict exactly what impact the regulators are going to have on the insurance industry. We all know that they will present a big challenge, against a backdrop of continued cost pressure across the sector. But what if there’s another AIG-type incident or another financial services scandal that infects the entire industry? That might spark another reassessment of the regulatory regime.
But that’s the point: no insurance company can afford to gamble on being able to muddle their passage through a highly unpredictable regulatory cloud without a centralised RO. If they do this they risk losing control of their costs, compliance failure (even if inadvertently through an error) and perhaps serious damage to both their reputation and shareholder value.

 

 

 

Finance

The potential of Open Finance and the digitisation of tax records

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The potential of Open Finance and the digitisation of tax records 1

By Sudesh Sud, Founder of APARI 

The world is undergoing huge changes at the moment. Between coronavirus pushing the economy to the limit and a group of Redditors challenging the financial market hegemony, people are questioning the role of established institutions. If finance doesn’t work to enable the economy, businesses or individuals, then who is it for?

Before the digital revolution, financial experts were seen as a necessity. They knew how things worked, what everything meant, could provide good advice and were employed to sit at the heart of the action. Now, trading can be done by anyone online through established platforms, with a wealth of information available to hand.

Yet, as the 2008 financial crisis proved, established financial institutions have made themselves too big to fail. Simply tearing down the existing financial system would leave many ordinary people, along with businesses and government treasuries, in ruin.

However, as legendary futurologist, Buckminster Fuller, once said: “You never change things by fighting the existing reality. To change something, build a new model that makes the existing model obsolete.”

Traditional banking models are already being upended by technology. Through Open Banking, challenger banks are able to connect services digitally, cutting inefficiencies and costs while speeding up transactions. Now, Open Finance is seeking to build on this model to connect financial services via technology, potentially making the existing financial model obsolete.

Just as Open Banking led to greater democratisation of money, Open Finance has the potential to transfer power back to individuals. Not only would this benefit society as a whole, but it would help minimise the boom-bust cycles that cripple entire economies. No individual would be too big to fail, and bailing people out would cost far less, having minimal impact on the economy overall.

With more information available to them, Open Finance businesses will be able to use technology to make better decisions instantly. Many people struggle to get onto the housing ladder due to a poor credit score, for example, yet they have been paying rent every month of their adult lives. Why, then, can they not access mortgages? A company called Credit Ladder is addressing this through Open Banking, reporting rent payments via challenger banks like Starling to credit agencies, helping good renters to access mortgages.

While it is still very early days for Open Finance, there seems to be an endless raft of possibilities to benefit individuals, businesses and national economies. Faster, more secure, and less risky access to credit can help grow the economy, transforming finance from something that benefits a few wealthy capitalists to something that enables growth in the real economy.

So how else could Open Finance benefit society?

Using Tax Information

Every working adult pays income tax. Some of us via self-assessment while others are enrolled in PAYE. Regardless, we all have tax records with a wealth of financial information that has been verified, at least in part, by HMRC.

This centralised repository of financial information could be put to better use, such as allowing credit reference agencies to better understand an individual’s risk profile or helping to prove income as part of a mortgage application. Unfortunately, HMRC is a black hole of information ‒ its sheer size and power sucks information in, but nothing comes back out again.

However, by Making Tax Digital (MTD), HMRC are effectively allowing individuals to keep validated tax records on the software of their choice. Software providers may then be able to use this information to enable certain aspects of Open Finance. The information doesn’t need to be protected by HMRC, it is the individual’s choice and responsibility over how to use their own information.

As MTD software develops, we will see it connected to Open Banking, allowing self-assessed taxpayers to connect their business account directly to the software, effectively getting their tax return completed for them by an AI program. They would simply check the details, add any adjustments, and click submit. HMRC would then validate the records, providing assurance for any financial institutions using that financial information.

More Growth, Lower Risk

With access to complete and validated financial information, lenders would be able to more quickly and accurately assess individual risk when considering a loan or mortgage application. This would greatly speed up the process of applying for a loan, whether for a business venture or property purchase, for example.

Take residential landlords, for example. They may own a few properties already, with equity coming out of their ears. If that landlord wants to obtain another property, they would need to get their accountant to assemble their financial information, complete a SA302, and send everything off to their mortgage advisors who would then validate the information before submitting the mortgage application.

The application can then take months to approve, slowing down the process and potentially leading to missed opportunities. Since property sales usually occur in a chain (the owner of the property you are purchasing is usually purchasing another property, and so on), these inefficiencies slow the process down for everyone and can have major impacts.

If, however, mortgage applicants could simply share validated financial/tax records, mortgage providers could use that information to make quick decisions with reduced risk. What’s more, applicants could share only relevant, high-level information, rather than expose their entire financial history.

Individual Risk Management

Currently, individuals can manage their credit score/risk profile via third party providers like Experian, Equifax and TransUnion. These credit reporting agencies use limited information, such as credit cards, store cards and loans to assess risk. Individuals need to understand what factors each agency uses in order to ‘game’ the system.

For example, someone who has always been careful with their money, kept to a strict budget and never taken out a loan or credit card will have a far worse credit rating than someone who regularly uses debt to finance their lifestyle. So, even though they may have amassed a good deal of savings, they cannot get a good deal on a loan or mortgage.

With Open Finance, these individuals would be able to quickly prove their earnings, spending, and savings, decreasing their risk profile in line with reality. Rather than crude measures of creditworthiness, financial institutions would be able to use accurate and validated information to make quick decisions based on realistic risk. This both transfers more power to individuals and contributes to faster growth while reducing overall risk.

As a centralised repository for validated financial information, MTD providers will be in a unique position to develop a two-sided marketplace for finance, allowing credit providers to match products to individuals’ risk profiles. When a customer needs a loan, credit card or mortgage, they can simply browse products for which they have already been approved, applying and receiving finance instantly.

Empowering PAYE Taxpayers

Currently, PAYE taxpayers have little, if any, visibility or control over their tax contributions. They will see the amount paid in tax and national insurance, but to claim any allowances requires them to submit a self-assessment tax return. For most PAYE taxpayers, this simply doesn’t seem worthwhile.

Yet, self-employed taxpayers can claim for things like travel to their place of work, a proportion of living expenses when working from home, even their lunch. These things are necessary for productive work yet, for PAYE taxpayers, come out of their already taxed income. Meanwhile, businesses tend to make use of every tax allowance available to them.

This imbalance could be rectified with Open Finance connected to tax software. As MTD becomes a validated system for self-assessed taxpayers, a new version could be developed for PAYE taxpayers, putting them in control of their tax and finances. Not only would they be able to benefit from Open Finance in the same way as self-assessed taxpayers, but they will also be able to claim for reasonable allowances. What’s more, HMRC/the Treasury/the government would be able to hold employers accountable for pay disparities and unreasonable tax avoidance.

Open Finance, then, has the power to speed up and reduce the cost of obtaining and providing finance. It would make the finance system fairer and most transparent while distributing financial power, and help to avoid the creation of too big to fail financial institutions and the boom-bust cycle that has become unfortunate features of modern capitalism.

Ultimately, Open Finance has the potential to help the UK and other nations recover from the seemingly unending series of crises that have plagued the early 21st century by allowing people to access finance quicker in order to grow their business and personal finances while reducing risk, inefficiencies, and costs.

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Finance

Three ways payment orchestration improves financial reconciliation

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Knowing the best alternative payment methods

By Brian Coburn, CEO or Bridge,

When Luca Pacioli, the 15th century Venetian monk, invented double-entry account keeping, managing financial reconciliations had its own unique challenges. The father of modern accounting didn’t have to deal with glitches in his book-keeping app but he did have to write with feather-based quills by candlelight. Five hundred years later the challenges are different but no less onerous.

As in the 15th century, solid financial reporting is at the heart of every successful high-transaction business. As Pacioli no doubt knew, up-to-date, well-documented accounting ensures good operational health and makes it easier to grow. And that’s never been more important.

While it might not be feather quills by moonlight, today’s environment of multiple customer channels can be time-consuming and labour intensive, with various payment methods and financial reconciliations from multiple data sources.

Understanding cash inflow through online transactions is a critical element of financial reporting. However, when these involve multiple payment processors and payment methods and a complex system of disjointed silos of payment data, this can become a cumbersome and arduous manual task.

Common issues in this fragmented payments landscape include working across different formats, managing different data owners and access as well as inconsistent process timings. The result is often increased inaccuracy and inefficiency. Procuring multiple tools and software can end up being uncost-effective and unwieldy. Though the current digital transformation is an exciting time for retailers, staying on top of the ever-changing payment options can be an overwhelming burden for many business owners.

Introducing payment orchestration presents a single, accessible, creative and accurate source of transactional data, crucial for today’s complex challenges around financial reconciliations.

Simplicity

Today, commerce is 24/7, so being able to access and analyse real-time information is vital to managing business controls. Many organisations have looked to automate these processes with account reconciliation software.

However, one key challenge is the sheer volume of transactions and the need to capture data from a variety of different sources. Payment orchestration enables transactions to be carried out by multiple payment processors and payment methods with simple and flexible plugins, centrally monitored and routed in the most optimum way.

It allows users to add or remove providers easily, knowing the complexity (detecting outages and automatically rerouting payments) is being handled by a trusted specialist partner via an intelligent platform.

Bringing disparate sources of online transaction data into one place simplifies how enterprises access and operate with multiple payment processors and payment methods. This makes it easier for businesses to remain agile.

Speed

For organisations that still depend on manual, spreadsheet driven processes, the mechanics of reconciliation can be extremely time consuming.

A payment orchestration layer creates the opportunity to automate processes and reduce manual intervention. By bringing multiple payment processors and payment methods into an integrated service layer with intelligent routing capabilities, the impact of individual outages or failed payments can be mitigated to ensure optimum payment success rates, saving crucial revenue.

Accuracy

Naturally, significant manual work brings with it the added risk of human error. The speed with which business moves today demands accurate accounting processes. Checking for error takes up valuable time that could be spent focusing on business growth.

Payment orchestration can improve accuracy and reduce the opportunity for error. Providing a holistic and central source of real-time transactional data, payment orchestration can offer improved transparency and greater visibility of financial data.

With all transactional data captured in one source, payment orchestration can present a data source to feed other applications – such as automated reconciliation tools and fraud management – automating business processes in a seamless way across the enterprise. Good practice like this will, of course, enable a consistent approach to fraud management across all channels and payment services.

Multiple payment choices can be onerous but, today, not adopting them at all is unwise. The key to success, and good financial reconciliation, is being able to streamline and manage them.

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Circular Economy must be top of the business agenda in 2021

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Circular Economy must be top of the business agenda in 2021 2

By Andrew Sharp, CEO of CDSL, the UK’s leading appliance spare parts distributor

The last year has been one in which we were all forced to change our behaviour. We have become far more familiar with the four walls of our home than we would have liked, we have had to give up the social activities that mean the most to us and we have spent much longer apart from relatives than we could have imagined.

But alongside the many reluctant changes that we have made, there have been some silver linings. Both consumers and businesses have reassessed their priorities, and we have seen a noticeable increase in the importance of sustainability and social value in everything we do.

Within this has been a rise in awareness of the power of the circular economy. Research from the Recycle Now campaign shows nearly nine out of 10 UK households now say they “regularly recycle” (September, 2020), while environmental organization Hubbub found that 43% of people are more concerned about plastic pollution than before Covid-19 (September, 2020).

The role of the circular economy in underpinning wider sustainability targets is now being widely realised by Government, consumers and businesses alike. The Ellen MacArthur Foundation recently found that circular economy policies contribute towards tackling the remaining 45% if greenhouse emissions that cannot be resolved by transitioning to renewable energy alone (January, 2021), and the circular economy can offer solutions to the 90% of biodiversity loss and water stress that traditional resource extraction and processing require.

However, reducing the impact of our current linear economy will require widespread change and every product that we use will need to be accommodated within this. One area that is yet to be fully incorporated into a circular economy model is e-waste – an area where the UK is unfortunately a world leader. Other than Norway, the UN has said that the average person in Britain discards more electrical items each year than anywhere else in the world, and the UK is also the worst offender in Europe for illegally exporting toxic electronic waste to developing countries.

1,000,000 tonnes of e-waste are produced annually in the UK, enough to fill six Wembley Stadiums. The WEEE Forum estimates that only 17.4% of e-waste was recycled in 2019 (October, 2020), meaning the vast majority of this is burnt or thrown into landfill, creating environmental hazards for years to come.

However, the good news is that 100,000 tonnes of e-waste would be avoided if we fixed just 10% more perfectly repairable appliances. As an electrical spare parts retailer, we have seen incredibly encouraging trends throughout 2020. Our leading consumer brand eSpares has seen record-breaking surges in demand over the past year as consumers look to fix appliances themselves rather than kicking them to the kerb.

We recently conducted a survey of 5,000 people and the results clearly show this growing interest among young people for repairing and recycling their electrical goods. The answers suggest that three times more young people than over-65s would try to fix a broken appliance at home and that the environmentally conscious under-35s are increasingly keen to fix gadgets rather than throw them away.

That is why we have taken steps to encourage our customers to drive a circular economy throughout the year with the campaign #FixFirst. As a business and a retailer, it is our responsibility to help educate our customers on the benefits of a circular economy. Free services like our Advice Centre, which has over 700 step-by-step articles and attracted 1.2million visits in 2020, contribute to this by offering assistance on making repairs around the home whenever and wherever it is needed.

It is up to businesses to ensure that we champion the benefits of the circular economy and ensure these behaviours are maintained permanently.

Certain sectors are already leading the charge in doing this. In fashion retail for example, Levi’s is paying consumers to bring back old pairs of jeans for sale on a second-hand marketplace. Patagonia similarly will take back old pieces of clothing to repair and refurbish them.

Plastic packaging is also receiving some tough attention from across the retail and food and drink manufacturing sectors. Tesco has announced that it has removed one billion pieces of plastic from its UK business in just one year through a policy of Remove, Reduce, Reuse and Recycle, while consumer brands like Nestle for example are testing reusable packaging to reduce the amount of single use plastics.

Consumer attitudes are moving in one direction on the topic of the circular economy and it is therefore essential that businesses also get ahead of this as a commercial priority. In 2020, Deloitte found that 43% of consumers were already actively choosing brands due to their environmental values, while 2/3 of consumers have reduced their usage of single use plastics. In direct to consumer in sectors like the one in which we operate, sustainability credentials are fast becoming a purchasing priority alongside price.

Legislation in the UK is also increasingly clamping down on businesses that do not champion circular economy in the products they create and use. The Environment Bill that is expected to be passed in Autumn will give Government powers to introduce new targets on waste reduction and packaging. Extended Producer Responsibility expected to be introduced in 2023 will also lead to major fees for manufacturers of products that cannot easily be recycled.

As the circular economy rises in priority over the next year, businesses must act fast. Robust policies on the circular economy will both drive environmental benefit and allow businesses to stay ahead of a trend that is fast becoming a priority for consumers.

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