Why I'm joining Passmore & Oliver — and why financial services regulation needs a different kind of adviser

Eight years at the FCA teaches you a particular kind of pattern recognition. You start to see, long before a firm does, exactly where a business model and a rulebook are heading for a collision — and you also see, more often than firms would like, how badly that collision can be handled once the regulator has to intervene.

Consumer Duty is the clearest recent example. The bar didn't just move from "not misleading" to "actively helping customers understand" — it moved from treating compliance as a set of documents or a tick box process to looking at the service through customers' eyes: understanding what they actually need, meeting it, and being able to show the exchange of value is a fair one. That runs through the entire customer journey, particularly the digital ones. Most firms I worked with, whether from the regulator's side or later at EY, were still organised as if the old model applied. That gap — between what good now looks like and what most compliance functions are actually built to do — is where a lot of my time over the next few years is going to go.

And this is the moment to tackle it. The consumer agenda remains a priority, but regulators are increasingly willing to say out loud that, in the years since the financial crisis, the balance between competition and regulation has tipped too far. Regulation is too often stifling innovation, preventing the development of services that would genuinely help consumers manage their money. Regulators are seeking to change their approach and firms have a generational opportunity to do the same: simplifying the business, stripping out regulatory overhead that never earned its place, and rebuilding around what customers actually need.

A perimeter that's messier than the rulebooks suggest

The other pattern I kept seeing had nothing to do with financial services rules at all. It was structural — and it is something consultancies have traditionally not been set up well to support. A law firm running a claims management business alongside its core practice. A group structure with a law firm on one side and a financial services business on the other, reporting into the same board. Firms exploring financial services activity as an exempt professional firm, which sounds like a narrow technical status right up until it means two regulators are effectively looking at the same organisation from two different angles.

The regulatory perimeter our clients actually operate across was never as clean as the rulebooks make it look.

Passmore & Oliver Partners have been aware of this from the start. That's also the edge that I kept observing: the perimeter needs to be viewed from both sides and between us we can amplify our particular expertise, our broad and deep domain experience, and that's the reason joining Passmore & Oliver made sense rather than staying inside a Big Four structure or setting up on my own. Crispin and Juliet have spent years on the legal-regulatory side of exactly this problem; I've spent mine on the financial services side. We can do much more together - for our clients and for regulators.

Why not just join another consultancy

I thought seriously about this. The honest answer is that most of the alternatives solve for scale rather than for judgement. A large consultancy gives you leverage, a global brand, and a lot of people between the partner who sold the work and the person actually doing it. What it doesn't reliably give you is someone senior thinking hard about your specific problem, because the economics of the model depend on junior time.

Passmore & Oliver works differently, and it was the deciding factor for me: no leverage model, no juniors learning on a client's time, senior people doing the work directly. That's a genuine constraint on how much the firm can take on at once — but it's also exactly what makes the advice worth having. The same calibre of regulatory insight as a Big Four practice, without the overhead that comes with it. In fact all three of us have worked inside regulators at senior levels, across legal and/or financial markets, and in fact in other professions too. That brings its own special insights that few can match.

Passmore & Oliver starts with the aim of building long term relationships with the firms we advise. Our goal is to remove unnecessary regulatory and consultancy costs.

What I'll actually be doing

From September, I'm building out a practice covering:

●       Market entry and authorisation strategy for banks, payment firms, insurers and fintechs

●       SM&CR implementation, from interview preparation through to ongoing accountability

●       Governance reviews and board effectiveness

●       Compliance strategy and operating model design — doing more with less, without quietly weakening control

●       Supporting firms manage their regulatory relations including regulatory review support and Section 166 skilled person reviews

●       Consumer Duty alignment, monitoring, and journey-embedded disclosure

Some of that will be firms who are exactly what people picture when they hear "financial services" — fintechs, challenger banks, firms with consumer credit or wealth management propositions. Some of it will be law firms and group structures who didn't expect to need an FCA-literate adviser at all, right up until they did.

An open door

If you're wrestling with any of the above — or if you're not sure yet whether you are, which is its own kind of problem — I'd genuinely like to talk. Not a sales conversation, just a useful one. My door is open.

None of this is a criticism of where I've been. I'm able to do this work because of what I learned at the FCA and, over the last four years, at EY — a firm full of genuinely smart people I hope will remain friends as well as former colleagues.