Managing your management
When we discuss regulatory compliance issues with our clients we often hear about the push back they receive internally from colleagues or management who see FCA compliance as an unnecessary evil. Because of this managers often devolve regulatory compliance to less senior personnel in a business so they can focus on sales and distribution.
However, when we point out the commercial advantages of minimising regulatory risk in a business its often a turning point and encourages greater involvement from senior management. With so much M&A activity in the UK intermediary space it has never been more important for brokers to protect the value of their business and ensure that the due diligence process is seamless and as pain free as possible.
Ideally firms will have a continuous programme of ensuring management are updated with regular MI on the performance of the business from a qualitative and quantitative basis but also with what’s on the horizon in terms of regulatory developments. The Regulator expects firms’ management to be fully aware of regulatory business performance so that any outliers are quickly identified, remedied and recurrences are prevented.
Sharing info up the chain on things like FCA Business Plan, FCA Consultation Papers and Market Studies together with commentary from compliance personnel ensures management understand whether their business will be affected by developments. Firms that have their own internal compliance support function will then be able to identity how the business is impacted operationally.
Firms that don’t have specialist support should consider having a generic project plan to cover all types of regulatory change – this can then be adapted for each development.
- Reviewing & updating processes and policies;
- Staff training;
- Impact on financial promotions, websites, disclosure documents, stationery etc;
- Management Information captured and reported on
- FCA Reporting implications
And don’t forget to evidence what actions have been taken; we see a lot of firms who are compliant with FCA requirements but who struggle to articulate this in the form of documentation such as meeting notes, record of updates to policies and procedures or a simple thing like version control.
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