Is the Pandemic- a regulatory challenge or opportunity?

More than 30 consumer protection measures in the UK have been put on hold since COVID outbreak. Regulators need to guard against lobbying to make these interim measures permanent. https://t.co/5lbFgbVXYF

— Josephine Cumbo (@JosephineCumbo) April 9, 2020

The incidence of opportunistic financial crime has so far been low. People cannot be liberated of DB pensions overnight. The incidence of financial self-harm may be much greater, we have no data yet on withdrawals from flexi-access drawdown since February. Nor do we know how much money has switched to cash or other “low-risk” havens.

We do know that the liquidity  is challenged, witnessed by the gating of most property funds. Where these funds are offered on third party platforms, it may be trustees and platform managers who suffer the reputational damage (rather than the fund managers). I have never heard of a “pandemic proof” financial solution and I am sure that a lot of risk-registers will be being revisited over the next few weeks.

Conventional notions of de-risking will need to be challenged as will abstractions such as “appetite for risk”.

There is a risk, which Jo Cumbo points out, that some people will consider our best way back to normality, is to rid ourselves of the hard-won consumer protections that result from a more open society. The risk is compounded by those who consider technology part of the problem – rather than the solution

This risk of regression

Mixed in with the naked xenophobia behind the “5G Coronavirus” theory, is  simple nostalgia. Burning a 5G mast is pretty extreme, but it comes from the same anxiety that I hear about Zoom. “what was wrong with life before we had 5G, the internet, the telephone etc”

Actually 5G and Zoom are far more likely to be part of the solution than the problem. They represent progression from the physical risks that will persist for many months until a general vaccination program for COVID19 is in place.

I am 100% in agreement with Jo Cumbo in calling for the reinstatement of the pension protections that are currently on hold. I also hope that the progressive policies to put information in our hands digitally – (the open finance initiative, more specifically the pension finder service and the pension dashboards)  – are accelerated – rather than canned. Covid19 should accelerate not repress progress.

 The rise of “Regtech”

Tomorrow I will be meeting with the FCA on Skype for Business . I have never printed a page of our application to be directly authorised or to enter the FCA Sandbox, nor do I intend to. FCA Connect isn’t perfect, but it serves us well.

We expect that all our interactions with the Regulator will be capable of being recorded for audio and video and that (with mutual consent), these recordings can be held in the cloud indefinitely.

This is analogous to our voluntary permitting our phones to permit tracking for potential touch points with COVID19.  Where people have the capacity to share records of their activities of daily living, then they should be free to do so. I recognise that some people do not wish to share with big brother, their every social interaction and the right to opt-out must be maintained.

But to me – the new normal – for consumer protection – will be a massive increase in data sharing, leading to a transparency of information where there will be a dashboard for everything.

If it can be measured, it can be managed.

A dashboard of everything offers infinite transparency. For Government – access to data is – right now – a matter of life or death.

We will almost certainly look back at this stage of the pandemic as defined by the capacity of Governments to access data on the spread of the virus to best martial limited resources.

The dispersion of fatalities between neighbouring jurisdictions suggests that Governments that get things right (for instance Germany and Scandinavia) are at an advantage to those who struggle (Italy, Spain , France UK..)

For those who say we should not progress our pension dashboard (as an example), then I would point to the varying trajectories of Covid19 spread over the past few weeks.

This may be a wake up call for Britain. Our underinvestment not just in pandemic preparations but in our capacity to organise and use data for the sake of public health, are now translating, very brutally , into a high daily death count.

We cannot duck these lessons or pretend that what happens in health, is not applicable in other areas of our lives. Preparedness for later life issues are of course linked to health after all.

We have an opportunity, as we stare down the barrel, to learn and progress. Alternatively we can bury our heads in the sand and spurn and regress.

We can have a dashboard of everything and use digital technology to deliver a better safer world. Or we can burn down 5G masts.

[Thread] 1/ Here’s an update on #coronavirus and 5g conspiracies on Twitter! Yesterday I downloaded around 43000 interactions (tweets, replies, rts, mentions, etc) from around 37200 unique accounts. That’s a lot of unique accounts. The sample was mostly from 6th-10th April pic.twitter.com/a6Z5exzFxr

— Marc Owen Jones (@marcowenjones) April 11, 2020