Did remote working really cause a drop in whistleblowing reports to the FCA?

A recent FOI response revealed that 2020 saw a 9 per cent drop in whistleblower reports to the FCA.  

Various industry publications picked this up (here, for example) and suggested that remote working has limited opportunities to discover potentially problematic conduct.

And the drop may have been, of course, one of the FCA's motivations for launching its "In confidence, with confidence" whistleblowing campaign in 2021.

Whether or not you think the FCA's whistleblowing efforts in general are adequate or deficient - and there are strong opinions on both sides of that fence - 2020's dip may have been less connected to remote working than the headline figures suggest.

Why?  Well, let's get more granular and look at the picture on a month-by-month basis throughout 2020.  

If the theory's right, then we would see a reduction in whistleblower reports beginning in April 2020 and sustained throughout the year. But that's not what happened.  

It's true that there were significant dips in April 2020 (immediately following the commencement of the UK lockdown in March) and in August-September and December (perhaps associated with people taking holidays and also the start of the November 2020 UK lockdown).

But reports recovered rapidly in June-July and again in October - months in which remote working in financial services remained widespread - to levels similar to those seen historically in 2014-2019.

So here's an alternative theory.  Whistleblowing is difficult. Whistleblowers make reports often at great personal risk. The transition to remote working, along with adjustments to lockdown, were inherently stressful - so in some (though not all) cases, whistleblowing simply slipped down the list of priorities until people's working and living arrangements were more settled.

And if that's true, then the FCA might be harvesting a bumper crop of reports in the tail end of 2021. Here's hoping they now have adequate resource to assess them promptly.