Early in the Second World War, Winston Churchill is reputed to have said “this is no time for ease and comfort. It is the time to dare and endure.” The Coronavirus outbreak has had a massive impact, affecting (I suspect) every business and family. With so many of us – me included – now working from home it requires a different focus if we are to ensure all of our businesses ‘dare and endure’.

At ICSR, by the very nature of our business model, we have always been set up to enable remote working and to address the challenges of distance working as the team are spread across a multitude of different client projects and locations. I’ll confess I didn’t plan the business model with Coronavirus in mind, but as my message below on Operational Resilience suggests, this is an opportunity for us all to learn something that we can translate into our future thinking.

We have all had to start doing somethings a little differently, but in talking with our team over the last few days, it is clear those currently engaged in client projects are easily adapting to the new working practices our clients have deployed and able to continue work on their client projects with continuing levels of vigour.

We do of course have other members of the team who are currently available and if you need short-term project staff to help your firm navigate the situation, please do talk to me about the options. You can take a look at the make up of our team here on our website.

This week, the FCA have said that they will be postponing the response dates for all live work. Interestingly, they have said nothing about the publication of their Annual Business Plan, something we expect them to release in April if they continue to follow their normal pattern.

Compliance and regulation will not go away. Aspects of the regulatory regime for banking and investment firms make the current social distancing expectations extremely hard to implement. In the insurance sector, we are fortunate that so many of us can adapt. But it is clear the FCA expect us to remain focused on their core mission of ensuring that whatever the challenges, firms act in a way that causes no harm to consumers. In other words, everything has changed but nothing has changed!

Operational Resilience

The core message from the FCA this week was: “The FCA stands ready to take any steps necessary to ensure customers are protected and markets continue to function well.” That said, it was no surprise they have delayed a number of key projects to enable them to focus on this, amongst them “CP19/32: Building operational resilience: Impact tolerances for important business services.”. That does not mean they are stopping work – rather that they see such significant risk of consumer harm from this situation that they have diverted significant resource to focus on preventing that.

In the spirit of ‘dare and endure’ I encourage you to take some time to reflect on how your business has implemented its contingency planning over the recent days and think about how you will report on the effectiveness of those plans if the FCA ask that question of your firm. It is my opinion that the FCA are very likely to look at the current situation as part of their assessment of the current state of play on Operational Resilience and you should be prepared to respond as part of the ongoing Consultation if and when asked in that context. It may be sooner than you think if it hasn’t already happened.

This is a subject we will be exploring more over the coming weeks and if you have any views, comments, questions or observations, I would be delighted to hear them. Please do feel free to drop me an email or give me a call.

As a country, we need to work together if we are to endure this crisis. At ICSR I have challenged our team to go beyond ‘endure’ and ‘dare’ to think about ways we can use what we learn from this situation to help make our business, and the businesses of our clients stronger.

On a very personal note, despite everything I have said on the theme of ‘dare and endure’, please make sure that first and foremost you look after the physical and mental health of your colleagues, family and of yourself.


Kenneth Underhill
Implement Compliance Solutions and Resources Ltd
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