Concluding Comments and Observations

      Concluding Comments and Observations


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      Full transcript available below:

      Welcome and thank you for joining today's webinar hosted by me, Bethany Sirven of MyComplianceOffice, and Gregory Brandman and Simon Collins of Eversheds Sutherland.

      To wrap up we've got just a few slides in what we've been seeing over request months. As we've alluded to, this is very much a change program that involves HR, legal, and compliance as three core limbs to getting under the skin of the regime. Particularly from a point of view of HR, it is a people regime change, so it's important there that HR is up front and center. Getting consistency across the firm is absolutely vital. Firms not getting it right. We are seeing some supervision, so skilled person reviews for firms who haven't managed to implement it is beginning to take place. Firms are also looking, for instance, to try and use this as an opportunity to just tweak their governance arrangements, looking at consolidation of some committees, et cetera.

      Certainly the firms that are subject to the regime at the moment are keeping quite a steady state of preparedness as the regulator is just beginning to flex its muscles a little bit more. Next slide please. We've touched on fit and proper arrangements and assessments already. I just wanted to put out a point here, again, around implementation. It's because it's taking longer to actually do the assessment because firms are being probably slightly more cautious. They're needing to link their F&P with their T&C requirements, and what happens if an assessment fails? This is why firms have formed a people or an F&P committee to consider issues that might arise. Don't underestimate, where there are issues, just the length of time it takes to sort those out.

      Next slide please. Some typical queries that we've seen, particularly as firms are beginning to think about their certified population, as Greg pointed out, those various different roles and responsibilities. Regulator doesn't particularly like role sharing, so be careful there if you're looking at particular roles there in terms of, I think, the learning has certainly been allocate it to one senior manager, the particular role. Escalation of issues, just to point out there keeping the regulator on side, timely, timely action is a good cultural barometer as far as the regulator is concerned. Firms looking again at what constitutes a conduct rule breach, so time taken to decide on what that actually is. Differences between whistle blowing and grievances, making sure you're getting that right, which is why people need to be well-trained to understand the differences there.

      I've just highlighted a few there. There are a couple of others in a sense that just link into things around performance management as well, and just going that extra mile in terms of understanding behaviors for managers and supervisors. Next slide please. These are some questions for yourselves to look at and consider in terms of just understanding, again, some of the dynamics that are going on in terms of particularly around HR aspects, particularly where you've got concerns over a particular individual, where you might be looking at disciplinaries, et cetera. It's all around the timing of bringing things together, giving yourself sufficient time to be able to get through what are enhanced requirements in terms of fit and properness overall for that certified population.

      Finally, just getting prepared and your next steps, if we can have the last slide. Effectively where we are looking now is if we're thinking it's coming in at the end of 2018, a number of firms as we saw from the poll have already started things going. Don't put it too much on the back-burner. Keep those communications going. Start working on the mapping in terms of roles, to responsibilities, and so on. Also, ensure everybody's involved in the process as well. It does touch on all areas of the business, as we've already mentioned. Be prepared for a bit of challenge around salaries, particularly as personal accountability is on the up, so from that perspective a number of individuals we've seen saying, "Well, I'm not sure I signed quite up for this. What about a little bit of increased salary?"

      That we genuinely haven't seen too much of, truth be known, but there will need to be changes to contracts, et cetera. 



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      This webinar was co-hosted with Eversheds-Sutherland

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