insurance products. Regulatory               and regulation. With regard 
   actions may also lead to                     to Solvency II, the capital 
   changes to the regulatory                    that we will be required to 
   and legislative environment                  hold will not be certain until 
   in which we operate.                         PRA agreement of our internal 
                                                model, with the risk that 
                                                the final outcome results 
                                                in a lower capital surplus 
                                                than under Solvency I. There 
                                                are also challenges in ensuring 
                                                that regulatory interpretation 
                                                of the new rules is proportionate 
                                                and cost effective for the 
                                                insurance sector. In terms 
                                                of consumer regulation, there 
                                                remains a need for greater 
                                                regulatory certainty to providing 
                                                consumer guidance and addressing 
                                                the advice gap in a post Retail 
                                                Distribution Review and an 
                                                increasingly digital world. 
 
                                                We remain vigilant to the 
                                                risk that future legislative 
                                                and regulatory change may 
                                                have unintended consequences 
                                                for the sectors in which we 
                                                operate. We seek to actively 
                                                participate with Government 
                                                and regulatory bodies in the 
                                                UK and Europe to assist in 
                                                the evaluation of change so 
                                                as to develop outcomes that 
                                                meet the needs of all stakeholders. 
                                                Internally, we evaluate the 
                                                impact of all legislative 
                                                and regulatory change as part 
                                                of our formal risk identification 
                                                and assessment processes, 
                                                with material matters being 
                                                considered at the Group Risk 
                                                Committee and the Group Board. 
                                                We maintain a flexible distribution 
                                                model to respond to changing 
                                                market trends. 
 
   The Group may not maximise                    As a significant participant 
   opportunities from structural                 in the long-term savings and 
   and other changes within                      insurance markets, we are 
   the financial services sector,                exposed to changes in consumer 
   adversely impacting future                    sentiment. We are also exposed 
   earnings.                                     to increased costs of regulatory 
   Significant changes in the                    compliance through regulatory 
   markets in which we operate                   and legislative responses 
   may require the review and                    to events in the financial 
   realignment of elements of                    services sector. Recent examples 
   our business strategy. A                      include requirements for central 
   failure to be sufficiently                    clearing of certain derivative 
   responsive to potential change                instruments, which would increase 
   and understand the implication                the costs associated with 
   to our businesses, or the                     pension savings products and 
   incorrect execution of change                 annuities, respectively. 
   may impact the achievement 
   of our strategic objectives.                  We actively manage our brand 
                                                 and seek to differentiate 
                                                 our business model from that 
                                                 of our competitors, focusing 
                                                 on our customers' needs through 
                                                 a diversified portfolio of 
                                                 risk, savings and investment 
                                                 businesses. We also actively 
                                                 engage with our regulators 
                                                 to support understanding of 
                                                 the risk drivers in the markets 
                                                 in which we operate, and highlight 
                                                 matters where we believe the 
                                                 industry needs to change. 
 A material failure in our 
  business processes may result                  Macro trends in the markets 
  in unanticipated financial                     in which we operate remain 
  loss or reputation damage.                     those of an ageing population; 
  We have constructed our framework              reform in the provision of 
  of internal controls to minimise               state welfare; retrenchment 
  the risk of unanticipated                      by the banks; the globalisation 
  financial loss or damage                       of asset markets; and the 
  to our reputation. However,                    increasing use of digital 
  no system of internal control                  technologies. Responding to 
  can completely eliminate                       these trends potentially creates 
  the risk of error, financial                   people and change risks, such 
  loss, fraudulent actions                       as organisational challenges 
  or reputational damage.                        and management stretch across 
                                                 the range of initiatives. 
                                                 Regulatory changes and political 
                                                 risks may also present complexity 
                                                 in delivering our responses. 
 
                                                 We've defined clear strategies 
                                                 to respond to the macro trends. 
                                                 We monitor as part of our 
                                                 on-going risk review processes 
                                                 factors that may impact our 
                                                 responses to these macro trends 
                                                 and seek to ensure appropriate 
                                                 risk mitigation plans are 
                                                 put in place. 
 
                                                 Our plans for growth inherently 
   The financial services sector                 will increase the profile 
   is increasingly becoming                      of operational risks across 
   a target of 'cyber-crime'.                    our businesses. We continue 
   As we and our business partners               to invest in our system capabilities 
   increasingly digitalise our                   and business processes to 
   businesses, we are inherently                 ensure that we meet the expectations 
   exposed to the risk that                      of our customers; comply with 
   third parties may seek to                     regulatory, legal and financial 
   disrupt our on-line business                  reporting requirements; and 
   operations, steal customer                    mitigate the risks of loss 
   data or perpetrate acts of                    or reputational damage from 
   fraud using digital media.                    operational risk events. 
   A significant cyber-event 
   could result in reputation                    Our "three lines of defence" 
   damage and financial loss.                    risk governance model seeks 
                                                 to ensure that business management 
                                                 are actively engaged in maintaining 
                                                 an appropriate control environment, 
                                                 supported by risk functions 
                                                 led by the group chief risk 
                                                 officer, with independent 
                                                 assurance from Group Internal 
                                                 Audit. 
 
 
                                                 The financial services sector 
                                                 continues to see attempts 
                                                 by third parties to seek and 
                                                 exploit perceived vulnerabilities 
                                                 in IT systems. Potential threats 

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