A Quick Checklist For Businesses
Have we planned, in good time, for all SMFs & CRs to receive training on the duty of responsibility, reasonable steps and the regulators’ guidance relative to them?
What steps do we need to take to ensure our has the ability to provide and obtain regulatory references for SMF and Certified roles?
Have we mapped our business against the regulator’s handbook so that we are aware of the impacting changes and where/who will be affected?
Are our record keeping facilities set-up to retain relevant documentation for at least six years after an individual leaves the business?
Have we identified potential conduct risks and implemented controls or mitigation measures?
Is our risk register up to date?
How do the board get made aware of conduct issues? (They are responsible for ALL conduct)
Have we prepared a formal and robust documentation of the firm’s governance arrangements into responsibilities maps and statements of responsibilities, setting out board and committee structures, roles, responsibilities & escalation lines?
Have we mapped existing SIF approvals onto the new SMF framework, and identifying staff potentially subject to the Certification Regime.
Are we ready to submit the new Form K?
Have we trained our staff on the impending changes?
Have we trained our staff on the Code of Conduct Rules?
Would your SMR preparations or current arrangements stand up to independent external scrutiny?
Is our Conduct Policy up to date?
Is our policy approved by the board?
Do you need to review the ‘state of play’ within your firm?
Do we need to have things checked by Compliance Consultant? (Hint: “Yes”)
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