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Understanding the FCA Culture and Governance requirements

The financial crisis placed banks under the public spotlight, the investigation into some of the practices revealed behaviors that caused public indignation, Payment Protection Insurance (PPI) is but one example.


This has created a necessary platform for cultural change in banking and the financial sector. Additionally, the Senior Managers and Certification Regime (SM&CR), which was applied to banks back in 2016, has clarified responsibility and accountability at the senior management level.

Culture has been acknowledged as a key root cause of the major conduct failings across financial services in recent history. The Claims management sector has fallen under the public spotlight for poor practice by some firms that have harmed consumers and standards in the sector.


As a result, on 1 April 2019, the FCA became the regulator of Claims Management Companies (CMCs) set up or serving customers in England, Wales, and Scotland.

CMCs that want to continue operating must demonstrate they can meet the FCA standards and follow its rules on conduct. it is important for your firm to address key drivers of culture and conduct including:

  • Purpose

  • Leadership