One of the first points which clients talk to us about is uncertainty around the final requirements. We’ve recently seen Omnibus II launched, which provided some clarity around the requirements, but it’s also raised questions. There are a number of concerns around the transition arrangements, which could potentially push out existing practices for up to ten years and that’s giving real headaches in terms of the overall programme.
But one of the overriding concerns should be how you actually engage with your regulator. Ultimately, if you’re a UK insurer, the FSA will have the final say on whether your model is approved or not. Engagement with the FSA is proving difficult if you’re not one of the high profile, high priority firms, which the FSA has selected. Many of our clients are actively engaged with the FSA which gives us valuable insights into how you can best work with the regulator, including proactively managing your meetings with them."