Georgina Philippou FCSI was only appointed COO of the FCA in November last year, but with more than two decades of regulatory and industry experience under her belt, she is already well versed in the nuts and bolts of the markets and regulation. 

Previously Acting Director of Enforcement at the FCA, her new role as COO involves making sure the regulator has everything it needs operationally, in terms of resources, people, finances, technology and equipment to ensure it can achieve its objectives in market integrity, consumer protection and promoting competition. 

Unique vantage pointThis track record gives her a unique vantage point to put into perspective the dramatic changes that regulation of financial services has seen in the last couple of decades. 

“Regulation feels very different to the way it felt when I first started 23 years ago,” she says. “The way it feels now is that it’s much more about making risk-based judgments, about making those judgments in the context where stakeholder views are taken into account and about being able to respond to events in a timely and practical way as they emerge. It is also much more about proactively having a voice in shaping the agenda for financial services in the UK.” 

Bolstering best practiceAnd as a long-standing CISI fellow, she sees dialogue with key industry groups like the Institute as a vital means of bolstering best practice. 

The sense of a greater burden of regulation is something that many in the financial services sector will share. Sometimes excessive compliance requirements mean regulators aren’t necessarily always the most popular people in the financial services industry. 

The FCA’s own remit has expanded dramatically. It is much wider than it was even a couple of years ago. “If you look at the last couple of years, the big headline issues – consumer credit, competition, the payments system regulator operating as an independent subsidiary of the FCA – that’s a lot to take in. And as our remit changes, of course we need to respond to that. So we might need to change, not just in terms of creating new rules, regulations and policies but in our wider approach as well,” says Philippou.

The sense that more is happening in the regulatory space is also a reflection of the increased complexity of financial services, and the need to respond to that. “We change because the environment changes. We’ve moved to a dual regulatory system – that was a direct response to the environment changing. There’s lots to do and a lot of it is very fast moving and reactive, but quite a bit is proactive and about shaping the agenda,” she says. 

She also points out that new requirements aren’t introduced without a thorough cost-benefit analysis. “We are very aware of the burden argument. We get a lot of feedback from firms and from the panels that present the industry views to us.”

Softer approach?The FCA came in for criticism after dropping plans in late 2015 for an inquiry into the culture and behaviour of British bank employees. But accusations that this means it is somehow adopting a softer line towards banks are untrue, says Philippou. “Banking culture is still at the top of our agenda. How can you be a conduct regulator without looking at culture?” 

In this particular instance, she notes, the FCA decided not to proceed with a planned thematic review about culture in banks. Better, it was felt, to find other ways of engaging on issues of culture. 

“We did our preliminary work over the summer, and got some useful information which we’ve fed back to firms. And one thing this showed us was that there might be more effective ways of proceeding than a thematic review, so we'll be taking this agenda forward in our day to day engagement with firms and encouraging wider dialogue,” she says. 

Transparency and fairnessOther probes remain firmly on the FCA agenda. In November, it launched an investigation into fund managers’ fees, even though these are not in the authority’s immediate remit. “It’s not an investigation into fees per se as we are not a price regulator,” says Philippou. “What we are doing is a market study to look at how competition is working and to ensure that it is in the interests of consumers. Above all we want to ensure that firms are being transparent in terms of fees. It’s all about transparency, fairness and value for money.” 

One of the big issues on the FCA agenda is the Senior Managers Regime and new requirements around accountability. This new regime is one of the main tools to take forward the authority’s culture agenda. 

Critics have said that the Senior Managers Regime makes life difficult for firms and easier for the FCA. But Philippou contends that the regime is really all about putting into place things that are good business practice anyway, such as having organograms and statements outlining senior managers’ responsibilities. “The truth is, not all firms have these, and it makes our job as regulator very difficult. Sometimes our enforcement cases would fall at the first hurdle as it was difficult to answer even basic questions about who does what,” she says. 

About Georgina Philippou

Philippou started her career as a researcher in a major accountancy firm before moving on to become an investment analyst for an institutional client stock broker and then a major investment bank

Philippou then joined the Securities and Investments Board (one of the FCA’s predecessor organisations) specialising in investigations. Georgina has extensive enforcement experience across all areas of financial services, including dispute resolution through settlement and mediation, involving a range of financial services firms.

In November 2015, Philippou became Chief Operating Officer at the FCA. She was previously Acting Director of Enforcement and Market Oversight, and prior to that was Director of Strategy and Delivery in the Enforcement and Financial Crime Division. Georgina also Chairs the International Organisation of Securities Commissions' (IOSCO) Committee on Enforcement and the Exchange of Information and its Screening Group. 

Georgina is a Fellow of the Chartered Institute for Securities and Investment.Cross-border co-operationAs head of two of the International Organization of Securities Commissions’ (IOSCO) committees, Philippou has collaboration with international regulators close to her heart. These committees have produced two major pieces of work. One is the Credible deterrence in the enforcement of securities regulation report published in summer 2015. The other looks into enhancing the IOSCO Multilateral Memorandum of Understanding (MMoU), which sets an international benchmark for cross-border co-operation. The MMoU’s importance rests on its role as a framework by which regulators make requests for sharing information with one another. 

The MMoU is now over a decade old, so it’s a good time to revisit it. “It’s almost impossible nowadays to imagine an investigation into major firms that doesn’t have a cross-border angle. That is increasingly a fact of life, and the IOSCO MMoU gives us the framework to share information and to progress those investigations,” says Philippou. 

Wariness about regulators is sometimes understandable, but in the end, says Philippou, much of the FCA’s requirements come down to good business practice. “What gets the headlines is the big enforcement stuff. People look at that and think all we are about is admonishing the industry. Yet enforcement is just the tip of the iceberg of our work. Every day, colleagues across the organisation are dealing with firms and working with them to resolve issues.”