Business Risk Assessment

The FCA requirements are that firms must identify and assess the risks inherent in all products, processes and systems. This means that an adequate risk assessment should be undertaken every time you launch a new product, implement any new processes, or change any system.

Once you have completed your inherent risk assessment, appropriate controls will need developing to mitigate your principle risks, and don’t forget ensure that your compliance monitoring arrangements monitor the effectiveness of your key controls.

For further details click here Business Risk

Approved Persons preparation

A minimum of 50,000 individuals will become Approved Persons under the new regime. Do you understand what’s expected of you by the FCA, if you need help in preparing to be an Approved Persons then give me a call.

Being an Approved Person brings with it a number of important responsibilities, including a duty to be aware of and comply with FCA regulatory requirements and expectations and also understand how they apply to the firms day to day activities. Click here for more details Approved Persons

Are you ‘READY, WILLING and ORGANISED’

Many firms new to regulation will be submitting their applications in October, but are you ‘READY, WILLING and ORGANISED’ thats the question the FCA will be asking. The authorisation process requires information about your business, your governance, your systems and controls, your strategy. Before you submit your application consider whether you are ‘READY, WILLING and ORGANISED’. Click here for further information. Ready Willing and Organised

Using a compliance consultant

To meet the requirements of the FCA Systems and Controls rulebook, in particular rule 6.1.1. A firm must establish, implement and maintain adequate policies and procedures sufficient to ensure compliance of the firm including its managers, employees and appointed representatives (or where applicable tied agents) with its obligations under the regulatory system and for countering the risk that the firm might be used to further financial crime.

It is each firms responsibility to ensure they meet the requirements of SYSC 6.1.1, every firm, large and small are responsible for ensuring compliance with the regulatory system, whether or not they use a compliance consultant. You cannot contract out your regulatory obligations, so if you are looking for compliance support you must ensure that the consultancy meets your needs.

Click here for the further information on Compliance Consultancy

Policy Governance

To meet the requirements of the FCA Systems and Controls rulebook, in particular rule 6.1.1. A firm must establish, implement and maintain adequate policies and procedures sufficient to ensure compliance of the firm including its managers, employees and appointed representatives (or where applicable tied agents) with its obligations under the regulatory system and for countering the risk that the firm might be used to further financial crime.

For more information click here Policy Governance

Conduct risk and treating customers fairly

Firms are now preparing their application pack ready for applying to the FCA for authorisation. It is essential that regulated firms can provide management information that evidences that Treating Customers Fairly (TCF) is central to their values and at the heart of their customer relationship.

The customer journey includes product design, marketing, distribution, advice, application and after care service. The customer outcomes must evidence that TCF is embedded within the culture of your firm.

Click here for the framework for Conduct Risk

Holiday reading

You may be about to jet off to the mediterranean on your summer holidays and considering a good book to read on the beach. Will it be ‘fifty shades of grey’  or my recommendation ‘executive’s guide to COSO Internal Controls’. An excellent book which will help you to establish a framework of controls for your business.

If you don’t fancy this as a good holiday read, then you can always give me a call.

Guidance on how to establish a control framework in line with COSO requirements

Risk Management and Internal Control

To meet the requirements of the FCA systems and controls rulebook, in particular rule 7.1.2 your firm needs to establish, implement and maintain adequate risk management policies and procedures, including effective procedures for risk assessment, which identify the risks relating to your firms activities, processes and systems, and where appropriate, set the level of risk tolerated by the firm.

Click here to see more Risk Management and Internal Control

FCA Authorisation Update

Between the 1^st June 2014 and the 31^st March 2016 up to 50,000 firms will be applying for either a variation of permission or authorisation. The authorisation application requires detailed information about your firm, its ownership and structure, your business risks, financial information, your regulated business plan, your corporate governance arrangements, your systems and controls, how you treat customers fairly, and how you monitor compliance with the rulebooks.

Your firm will be required to submit certain key documents and may be required to submit other policies and procedures to support your application.

The FCA recently held a round table event for trade associations which focused on the authorisation process. This is a high level summary of the key points raised:

• Early experience of the applications received so far suggest that firms were finding it more difficult and time consuming to complete the form than they had expected, so it is important that firms make sufficient time to complete the application.
• Firms must provide full documentation as required and be open and honest. Without all the information and supporting evidence the FCA do not class the application as complete, leading to delays and requests for more information.
• Make sure you apply for the right permissions at the right level.
• Do not miss the application slot assigned to your firm as your interim permissions will immediately lapse and cannot be re-instated if you do. The FCA has no scope to consider late applications and firms will be expected to cease trading until authorisation has been obtained.
• Application periods have been assigned on the basis of the OFT categories which firms held as of the 1^st April 2014. These will not vary even if a firm has applied to vary its categories.

If you require any assistance with the application process please call or respond on the website. We will endeavour to respond to you at the earliest opportunity.

Tel mobile: 07597 386728

e-mail: info@internalcontrol.co.uk

Web: www.internalcontrol.co.uk.