John Swift QC, the Independent Reviewer appointed in respect of the review of the supervisory intervention on Interest Rate Hedging Products, has now completed his discovery exercise and recently provided the FCA with his draft report.
There will now be the usual fact-checking and representations process with the report expected to be finalised and published in summer 2021.
The FSA/FCA’s intervention on Interest Rate Hedging Products involved a number of regulated entities and skilled persons and covered the six-year period from 2012 to 2018.
Since the start of the Independent Review, in July 2019, the FCA has provided John Swift QC and his team with approximately 1 million documents, over a 15-month period from this date, that were potentially relevant to his review.
John Swift QC has also conducted a large number of interviews with stakeholders including former and current FSA/FCA employees, IRHP customers, banks and skilled persons.
However, the number and the complexities of the issues under review, and the large volume of material to be considered and analysed, and the effects of the coronavirus (Covid-19) pandemic over the whole of last year, presented challenges for the provision of documents and the conduct of the Independent Review. This combination of circumstances has meant the Review has taken longer to progress than was initially anticipated.
Background
The Review was commissioned on 20 June 2019 by the Non-Executive Directors of the Financial Conduct Authority (FCA).
John Swift QC was appointed on 20 June 2019 to carry out the Lessons Learned Review into the supervisory intervention on IRHPs.  Under the Terms of Reference, the Review was to be completed within a period of 15 months beginning on the date Mr Swift was appointed by the FCA.
Under Paragraph 9 of the Terms of Reference, if the Independent Reviewer considered that it was not be possible to complete the Review within the period of 15 months from 20 June 2019 (i.e. by 20 September 2020), he was required to inform the FCA of:
(a) the reasons for the delay in the conclusion of the Review; and
(b) a revised target date for the conclusion of the Review.
The target date was previously revised on 20 March 2020 to early 2021.

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There is no need for investors to do anything. Investors should shortly receive an update from the Joint Administrators through The House Crowd’s platform with further information.
The Joint Administrators are now responsible for the business of The House Crowd. Among other things this means that they will seek to operate the P2P platform and manage loans as normal. Information on the progress of the administration will be posted on Quantuma’s website as it becomes available.
Investors will continue to be bound by the terms and conditions which they have signed up to. Updates will continue to be provided through The House Crowd’s platform.

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Financial services technology is constantly updated, but when firms implement changes they don’t always go to plan. The coronavirus pandemic has also required firms to implement change quickly and move to new ways of working. Although many changes are successful, this review reveals that failed technology changes are one of the main causes for operational disruption within firms, accounting for a quarter of all high severity incidents that cause harm to consumers and the market.
We found that changes made by firms with strong governance and risk management strategies are more successful, that robust testing is an important part of the change process, and while testing automation has benefits it also presents challenges. We also found that pairing subject matter expertise with a clear understanding of a firm’s strategy is vital.  
We know that firms must regularly upgrade their IT systems and while we do not expect changes to be implemented without incident, firms can work towards reducing the disruption caused, making themselves and the wider industry more resilient. And while the coronavirus pandemic has caused some delay to planned technology changes and system updates, it is very important for firms to understand how technology change activity can affect the services they provide, and invest in their resilience to protect themselves, consumers and the markets. This is especially important as firms increasingly use remote and flexible working.
The report intends to support discussions on how to reduce the frequency and severity of disruption due to technology change activity. Firms should consider the findings when assessing their future technology changes. This includes investing in technology to protect themselves, consumers and the markets.

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