Financial services firms have been seeking clarification from regulators in respect of non-financial misconduct (“NFM”) for quite some time. It has been 5 years since Christopher Woolard, then Executive Director of Strategy and Competition at the FCA, stated that “non-financial misconduct is misconduct, plain and simple”, however the precise parameters of how non-financial misconduct is treated by the regulator has remained unclear and undefined.
Perhaps it is not so “simple” after all.
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