As the FCA 2015-16 Business Plan starts to come into effect, with the British public becoming increasingly aware of its implications on their finances, Unicorn Training’s Mark Jones asks does your training strategy do what your staff want?
“We are seeing a degree of external regulation via the financial standards authorities. But also I think there is a new improved culture, and cultural change, which is ongoing via the internal changes, where senior managers are going to be very much more charged with the compliance of rules and regulations.”
When Jeremy Stretch, Head of Currency at CIBC World Markets, talked about banking and market regulation ahead of the Chancellor’s Mansion House speech in mid-June, he did not say anything anyone in the industry would not be familiar with.
But this interview took place on BBC Radio Five Live’s Drive show at 5.45pm, midweek during rush hour and at audience peak. FCA regulation and the impact on the wider population are starting to seep into the mainstream.
And at a time when Governor of the Bank of England, Mark Carney, has once again talked about eradicating the “culture of impunity” and how trust in the markets has been eroded, public scrutiny will only intensify as the new regulation rolls out.
When the FCA launched its 2015-16 Business Plan in March, at its heart sat strengthening integrity in wholesale markets by looking at disclosure and conflicts of interest, protecting consumers by tackling poor practice in consumer credit, monitoring how industry addresses changes in pensions sector, seeking to influence development of global standards and implementing EU legislation and driving cultural changes in firms by enhancing accountability of individuals.
Across the whole of the financial services industry, embedding a culture of ethical behaviour is no longer simply about compliance, it is also part of greater professionalism and is also a source of potential competitive advantage. The alternative? The real threat of jail time.
‘Senior Manager’s Regime’, ‘MiFID II’, ‘Mortgage Credit Directive’, ‘certification’, ‘code of conduct’, these are all current mots du jour and, more importantly, triple-lined, red circled notes on calendars as to when compliance requirements must be met.
In his Five Live interview, Mr Stretch stressed that the scrutiny from the new regulator was driven by a “few bad apples” and not failings of all businesses. But while that is largely true, having the regulated policies and procedures and reporting processes in place to keep the regulator at bay is an industry-wide concern.
So how is your approach to training and competence reflecting this?
Arguably the most critical factor is time. Your staff need to be aware of the things that affect their everyday working lives and able to behave accordingly; much else is superfluous and runs the risk of compliance returning to the days of ‘tick box regulation’ rather than embedding cultures of genuine change.
Learning professionals and their staff increasingly prefer ‘snackable’ chunks of learning that can be digested little and often
The days of sitting 30-minute computer-based learning modules and assessments once a year to prove compliance are on the way out. They are not effective in driving improved behavior and can be repetitive and time consuming in a world where time is at a premium.
Learning professionals and their staff increasingly prefer ‘snackable’ chunks of learning that can be digested little and often – for example on the train or between meetings. Little and often can be far more pervasive learning that can drip-feed into the learner’s subconscious, and if well designed, may also be engaging rather than seen as a tedious mandatory chore.
Another important development is the availability of diagnostic tools, such as that recently launched in the CII Assess product. Diagnostics will identify an individual’s learning gaps by reference to their required job role competencies, and then recommend or mandate the appropriate learning to meet the gaps.
Learners want their learning to be contextualized too – it has to reflect their world and the scenarios they encounter whilst fulfilling their varied job roles. Anything else is a waste of their time and yours as their employer.
Give a wealth manager learning more relevant to retail banking, for example, and it is unlikely the learning will be seen as relevant.
However, there is an extremely fine line between minimising the impact of training on people’s high pressure working lives and actually nurturing the outcomes your business desires and the regulator demands. This is why compliance should be treated as part of, not in isolation to, an individual’s whole career development plan.
Employees have to value what they are doing in terms of how it affects their promotion prospects, earning power, professional pride and reputation, with the by-product being the benefits that brings to your business both commercially and with regards to regulatory compliance.
Apps and mobile learning, with on and offline syncing, will increasingly drive the delivery of this. Our own learning and development platform, SkillsServe, already allows individuals to access their personalised learning plan on the move, with courses developed to meet the demand for ‘snackable’ learning at the point of need.
A learning programme could typically comprise five or six short elements, spaced out over a period of time. For example:
- a short video to engage the learner – the “what’s in this for me?”
- a diagnostic assessment to help a learner focus on what they really need to know
- a PDF with memorable infographics to summarise key elements
- self-paced, interactive learning to provide more detail on key messages
- role-specific scenarios to help learners apply their new knowledge in a realistic simulated environment, where they make decisions and can see the consequences of those decisions
- a final assessment
It is this point that you really start to effect changes in behaviour, with learner progress and results tracked and reported back to your learning management system, updating the individual’s training plan and providing vital management information.
With over 26 years’ experience providing learning solutions to the financial services sector, Unicorn has seen many changes in the regulatory environment. This is the latest, but it certainly will not be the last. Having established partnerships with leading professional bodies and consultants, such as FSTP, we can help ensure the right learning can be delivered to the right people at the right time, resulting in the best chance of genuine changes in behaviour.
As Jeremy Stretch observed after Mark Carney’s latest critique of ethical standards in banking, there has certainly been a change in culture within the City over the course of the past couple of years. The new beefed-up sanctions for non-compliance will undoubtedly serve as a deterrent, but it is building and sustaining an ethical business culture that will ultimately win the war.
