Reference Case Number: FOI11994
Freedom of Information: Right to know request:
- The number of firms visited since the survey.
- Copies of any and all follow-up requests for information sent.
- The number of enforcement actions begun against firms.
- Minutes of meetings with trade bodies or similar organisations that reference the survey.
On 31 January 2025, you clarified that by ‘visits’ you refer to wider engagement, including calls, in-person visits, and any other engagements, asking if we could provide details of these as separate categories. On the same date, you also clarified that you are seeking information about enforcement actions begun against firms as a result of follow-up work around the survey.
FCA response:
Please note the following information relates to our contact with firms which occurred solely because of the survey. Firms’ survey responses have also been covered in wider firm engagement where, for example, we have a connected supervisory workstream or are addressing a reactive case. These engagements are not included in the response below. Additionally, our response covers engagement that happened on or before 31 January 2025 when you clarified your request; further engagement with firms has happened since and is planned.
1. The number of firms visited since the survey (including calls, in-person visits, and any other engagements)
Following the survey, we held calls with 14 firm entities made up of wholesale insurers and wholesale insurance intermediaries (collectively ‘wholesale insurance firms’). In some cases, entities representing multiple firms that may have responded to the survey as a consolidated ‘group’ firm submission. The purpose of these calls was as a qualitative follow-up to the firms’ survey responses.
We emailed 26 firm entities made up of wholesale insurance firms with a follow-up request seeking clarification of specific aspects of their survey responses. We also contacted 26 wholesale insurance firms separately by email as they had not responded to the original survey submission.
We emailed 15 wholesale banks and 37 wholesale brokers. We also held calls with 4 wholesale brokers following the survey. The purpose of these emails and calls was to request a qualitative follow-up to the firm’s survey responses and / or to request further information about specific aspects of their survey responses.
We have proactively engaged with 4 firms (2 wholesale insurance firms and 2 wholesale banks) in relation to the survey as part of ongoing supervisory work. As mentioned above, in order to respond to your request, we have identified relevant engagements with firms as far as is possible. The survey may also have formed part of other ongoing discussions with firms that we are engaging with for other reasons.
2. Copies of any and all follow-up requests for information sent
We can confirm that we hold the information you have asked for, but we are prohibited from disclosing it to you, as it constitutes ‘confidential information’ for the purposes of section 348 of the Financial Services and Markets Act 2000 (FSMA), which the FCA has received in the discharge of its public functions. It is also possible for ‘received’ information to be embedded within information created by the FCA, and such information is also exempt from disclosure under section 44 of FOIA. We are therefore exempted from the duty to disclose this information under section 44 of FOIA. For more information on why this exemption applies, please see Annex A.
3. The number of enforcement actions begun against firms
We have interpreted this question as relating to actions taken as a result of investigations in which investigators have been formally appointed under any of the relevant subsections of section 168 of FSMA. On that basis, we can confirm that no investigations have been opened as a result of the recent culture and non-financial misconduct survey to date.
4. Minutes of meetings with trade bodies or similar organisations that reference the survey.
We can confirm that we hold the information you have asked for, but we are prohibited from disclosing it to you, as it constitutes ‘confidential information’ for the purposes of section 348 of FSMA, which the FCA has received in the discharge of its public functions. It is also possible for ‘received’ information to be embedded within information created by the FCA, and such information is also exempt from disclosure under section 44 of FOIA. We are therefore exempted from the duty to disclose this information under section 44 of FOIA. For more information on why this exemption applies, please see Annex A.