A number of common red flags for unadopted compliance issues exist in the small, regulated firm.
Outdated SMCR Responsibility Maps
If Senior Managers’ Statements of Responsibility are not up to date following a change to a role, then you have an immediate problem. Understanding the Small-Sized Firm regime within the SM&CR is crucial to understanding that responsibility must be accurately assigned at all times, not just at authorization.
Policies That Have Never Been Tested
The existence of a policy document on a folder does not prove anything. It is crucial that all policies are put to the test and verify whether they are up to date and reflect the current FCA rules.
A Complaints Register With Holes In It
The FCA expect a full and accurate record to be kept of all complaints and for these to be updated to reflect the full outcome of each.
Training Records You Cannot Produce Quickly
When a request for staff training evidence is asked for and you need days to locate these documents, this will be an issue. Up-to-date training records, with a date and name attributed to each piece of work, should be able to be located and sent within an hour.
A useful reference for FCA Compliance Consultants is //www.adempi.co.uk/.
Acting early will allow you to address any issues before they become a problem.
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