As we all know, in the Financial Conduct Authority (FCA) Handbook, Systems & Controls (SYSC) Chapter 10, Rule 10.1.10R states; Conflicts policy

• A management company and an insurance intermediary must establish, implement and maintain an effective conflicts of interest policy that is set out in writing and is appropriate to the size and organisation of the firm and the nature, scale and complexity of its business.

Additionally, ethical behaviour also has to apply. SMCR is all about conduct and responsibility, and this can sometimes lead to ethical dilemmas.

We can help you identify cultural hotspots, create a better culture, reduce ethical dilemmas and manage any conflicts of interest properly.

Gone are the days when GRC responsibilities were relegated primarily to the second and third lines of the business. Today, the focus has shifted to the front line because it is there that risks are taken and where the consciousness around risk management and compliance needs to be pervasive.

Since the front line is closest to the risks, they are often better positioned than an intermediary risk function to anticipate and assess their own risks, while also managing their own compliance with regulations, laws, and policies.

Greater ownership of GRC by the front line helps organisations gain better control over risks and minimize both regulatory and reputational issues. It also reduces the need for costly and complex risk monitoring processes.

Staff training is key to leading a successful business, and we are not talking about the same regurgitated refresher training that is available.

We have an online training platform with over 200 courses available HERE.

The best training with your staff and Senior management is facilitated by a knowledgeable and experienced trainer. All of our Compliance Consultants have a minimum of 5 years (often many more) experience as a Compliance Manager or higher and are all qualified to at least QCF Level 4 level (often Level 6+). Call us for details on 0800 689 0190.

There is nothing worse than attending training courses run by academics with no real industry experience. Our courses are built and delivered by compliance people for compliance people. Only an experienced and qualified trainer can provide anecdotal evidence, and answer real world questions and make the subject feel alive.

All of our Compliance Consultants have a minimum of 5 years (often many more) experience as a Compliance Manager or higher and are all qualified to at least QCF Level 4 level (often Level 6+).

See a sample of face to face courses HERE.  We do have a training platform with our course list HERE.

Call us for details on 0800 689 0190.

We can do suitability checks on all types of sales files even DB pension transfer reviews. Suitability is the most typical but sometimes we can do call monitoring for set procedures and including the statutory requirements.

Past Business Reviews are also a growing areas where we can offer cost-effective and professional reviews with full reporting and spreadsheet data for analysis. We can do internal QA or leave it for your team.

We have designed and operate a proprietary checklist than can be adapted or used as-is. It is aligned with the FCA methodology and provides plenty of room for narrative and recommendations. ANd, don't forget, all our Compliance Consultants have a minimum of 5 years (often many more) experience as a Compliance Manager or higher and are all qualified to at least QCF Level 4 level (often Level 6+).

As we know, a vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm - particularly when a firm is not acting with appropriate levels of care.  Is your firm operating appropriately and not just putting their name on a register?

Published in 2021, the FCA state "Our Financial Lives coronavirus panel survey, carried out in October 2020, demonstrates that more consumers find themselves in vulnerable circumstances due to the pandemic, with 53% of adults displaying a characteristic of vulnerability. This is an increase of over 3 million since February 2020, and many of these people may have multiple characteristics of vulnerability."

Call us for details on 0800 689 0190.

The FCA approach suggests that conduct risk is associated with the firm of employees' activities that could threaten consumer protection or market integrity. The Senior Managers and Certification Regime (SMCR) for example increases accountability for senior members of financial services firms for their conduct.

How do you take reasonable steps to counter this risk? How do you quantify it in the first place? What are the drivers? What are the 5 questions I should be asking?

Call us on 0800 689 0190 to discuss your needs.

Regulatory fines are abundant in the industry and 2021 saw an end of year surge causing the value of fines handed out by the Financial Conduct Authority to jump to £577m.

"Omar Hussein" (fined £116k) was the highest individual fines at £116,000 for pension transfer errors. "Crossfill & Archer Claims" (fined £110k) for unsolicited calls and a former CF10, "Simon John Varley" (fined £68.3k) including FIT breaches - Lack of honesty & integrity.

Fines can so often be avoided if the right things are measured and mitigation plans are executed. Call us for details on 0800 689 0190.

We should all know and understand what could be a complaint, but when did you last test it in your business. When was the last training delivered and have you done an independent audit on a sample of complaints to provide comfort to the board that you are on top of the situation? Have you taken all reasonable steps to identify, quantify, mitigate and measure?

Call us for details on 0800 689 0190.

What does the FCA expect on fair value?

One of the core challenges of the Price & Value outcome is the subjectivity aspect: what may superficially appear to be a reasonable price for a product or service from a firms’ perspective is likely to be informed by their own biases or over-reliance on the perceived mark ‘norm’, making it difficult to ‘check your own homework’ through an objective lens.

Firms should be mindful that the market ‘norms’ they may have historically used in their rationale are also changing as the result of the new Consumer Duty – and they can no longer rely on them for comfort.

What’s more, the regulator has been clear that it favours a principles-based, outcomes-focused approach for the Consumer Duty – as opposed to setting hard-and-fast rules – meaning there’s no set roadmap for businesses to follow. And so, despite the huge number of metrics and factors at play, firms will need to devise their own criteria and monitoring strategy that fits their own business model.