GABRIEL - FSA financial reporting

Open letter to Hector Sants

Why has the FSA forced the IFA community to act as Beta testers for a piece of software that is, at this moment in time, not fit for purpose?

If sufficient testing was done then the testers have been negligent. If it was not done then the individual(s) who authorised the launch have been negligent. Who is responsible and why, until the system is working, have they simply not reverted to using the previous system?

Surely, as a test, data could have been transferred from one system to another.

The use of computerised data input is supposed to save time on both sides i.e. the FSA and the adviser community. The waste of adviser time does not appear to have been factored in and no one is taking responsibility. No explanation is being given and no time scale for when the system will be up to speed.

Is it a software problem or a hardware problem? 'Due to a high level of demand' is given as the reason. If this is indeed the correct explanation. Who is responsible for this poor forecasting of demand?

Evan Owen
IFA Defence Union

How does the introduction of GABRIEL comply with section 7 of the Statutory Code of Practice for Regulators.

7. Information requirements

Hampton Principle: Businesses should not have to give unnecessary information or give the same piece of information twice.
Effective regulatory work, including risk assessment, requires accurate information. However, there are costs to its collection both to the regulator
and to regulated entities. It is important to balance the need for information with the burdens that entails for regulated entities. As such, regulators must
have regard to the following provisions when determining general policies or principles or when setting standards or giving general guidance on data
requirements.

7.1 When determining which data they may require, regulators should undertake an analysis of the costs and benefits of data requests to regulated entities. Regulators
should give explicit consideration to reducing costs to regulated entities through:

• varying data requests according to risk, as set out in paragraph 4.3;
• limiting collection to specific regulated entities sectors/sub-sectors;
• reducing the frequency of data collection;
• obtaining data from other sources;
• allowing electronic submission; and
• requesting only data which is justified by risk assessment.

7.2 If two or more regulators require the same information from the same regulated entities, they should share data to avoid duplication of collection where this is
practicable, beneficial and cost effective. Regulators should note the content of the Information Commissioner’s letter11when applying the Data Protection Act 199812 in
order to avoid unnecessarily restricting the sharing of data.

7.3 Regulators should involve regulated entities in vetting data requirements and form design for clarity and simplification. They should seek to collect data in a way that is
compatible with the processes of regulated entities and those of other regulators who collect similar data.