Is the Institute and Faculty of Actuaries stuck on playing its disciplinary records as loud as it can?

There's a tempo marking by the legendary jazz pianist and composer Fats Waller: tempo di-sturb de neighbours.

I don't know about the neighbours, but the IFoA seems intent on playing its disciplinary mood music far louder (between 10 to 20 times louder) than its American cousins.

Why is it that IFoA actuaries (and principally UK ones at that: the IFoA disciplinary scheme seems to be applied disproportionately to ones working in the UK) are disciplined 10 to 20 times more than SOA (Society of Actuaries)/CAS (Casualty Actuarial Society) ones?

To such an extent that ￡2.6 million was spent in a year on "discipline and regulation", which given the typical annual volume of IFoA disciplinary cases of about 20, amounts to a staggering ￡130,000 per case. Since half the cases are typically dismissed as having no case to answer, this amounts to an even higher amount for each case which has gone through the sifting processes. What were the IFoA doing? Did they take a leaf out of the Post Office and employ Lord Grabiner QC at several thousand pounds an hour?

A glaring disparity compared to other major actuarial organisations

Are UK IFoA actuaries really 10 to 20 times more prone to commit misconduct than their (US) SOA/CAS colleagues? The IFoA could usefully provide an explanation for this massive disparity, but it has failed to do so.

Why not? I suspect because the reason for the disparity is the old one of apples and pears. IFoA fish swim no closer to the fishermen than their SOA/CAS counterparts, but the IFoA has widened the scope of its disciplinary net to be about ten to twenty times wider than that of the SOA and CAS, so of course it catches far more fish.

Just imagine if the IFoA brought its disciplinary fishing expeditions into line with those of the SOA/CAS (and who knows, the majority of other actuarial organisations?): what would happen to its annual disciplinary/regulatory spend?

￡2.6 million for 20 cases already brings to mind Lord Grabiner QC of the Office of Post (as Private Eye put it so well in its depiction of Saint Paula [Vennells]). But if the IFoA suddenly started acting consistently with the SOA/CAS then the number of cases would drop to 1 per year on average. In that situation I suspect that even the IFoA would realise that spending much more than a few hundred thousand pounds would be pushing its credibility with its members to its limits.

Of course, I'm not seriously suggesting that the IFoA really has been employing barristers as expensive as The Right Honourable The Lord Grabiner KC. The truth is we don't know what the IFoA spent the money on, because other than providing the headline figure of ￡2.6 million, they haven't said.

We don't even know how much was spent internally (on staff) as opposed to externally (e.g. on outside solicitors and barristers). But let's assume for the sake of argument and ease of example that half of the money was spent internally and half externally, and at more down to earth rates than the Right Honourable Lord G's. Perhaps ￡1.3 million would cover 13 in house lawyers for a year, and perhaps a slightly smaller number of outside lawyers, paid lay panel members and legal advisers.

If the IFoA behaved like the SOA and CAS, then using an army of 13 in house lawyers and say 10 external personnel to deal with 1 or 2 cases a year would be ... clearly ludicrous.

So if the IFoA brought its disciplinary appetites into line with those of the other major actuarial organisations, then it is likely that several in house lawyers and external lawyers and panel members would become free to perform their services elsewhere.

And a significant chunk of members' subscription fees would become available either to reduce such fees, or to be spent on other (arguably more productive) benefits to members.

And a significant chunk of members' subscription fees would become available either to reduce such fees, or to be spent on other (arguably more productive) benefits to members.

But what has the IFoA done? I understand that it has been increasing both staff and member subscriptions. Perhaps the extra member subscriptions are needed to pay for the extra staff? And why are more staff needed? Well since we have established above that the IFoA's much wider disciplinary fishing net has lead to more internal and external staff being needed, and to higher subscriptions from members to pay for these extra disciplinary and regulatory costs, could the extra staff be arising from the IFoA's plans to widen its disciplinary net even further (by embedding the divisive, Marxist and anti-free speech - and hence anti democracy - DEI ideology in the Actuaries' Code)? Perhaps the IFoA should explain.

An industry addicted to high regulatory/disciplinary expenditure?

Has the IFoA become addicted to growth in legal/staff costs which become a self fulfilling prophecy ("We are going to get more disciplinary cases so we need more staff/resources")?

Isn't there a danger of moral hazard here? The DEI ideology has become a sort of cottage industry: like political commissars in the Soviet Union, every company/organisation must employ a full time DEI officer, otherwise it is accused of not caring about diversity/ not taking it seriously. If the DEI officer fails to find evidence of problems, then don't they risk putting themselves out of a job?

Similarly, the wider the scope of disciplinary investigations (in particular from imposing DEI ideology), the greater the demand for investigators/lawyers/panel members with DEI views.

How many people in the UK owe their livelihood to DEI ideology? What is the evidence that it adds value, and that such value is greater than the opportunity and other costs that it imposes?

If I were still a member I would be telling the IFoA to turn the volume on its disciplinary dial back down from "tempo di-sturb de neighbours" to normal levels.

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