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Common Questions and Queries

Common Questions and Queries



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Full video transcript available below:

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

References, Greg has covered, as with delegation. Those are intended to be that the key areas. I'm just going to comment now, if we can have the next slide, on some of the things we've just been seeing. Some of the questions that we get back.

Linking back to that polling question, the role of HR, legal, and compliance, getting the project thing structure right. What we have seen is HR upscaling its regulatory knowledge and therefore trying to ensure that there's a consistency of approach across the firm dealing with stuff matters. A number of firms have had issues whereby one particular area of the firm is dealing with perhaps a disciplinary situation, or maybe a fit and properness issue, and there's a differing opinion coming from another department elsewhere within the firm and just making sure those things aren't joined up.

We have seen some activities from the regulator warefirms. Haven't got the embedding of the regime right with skilled person reviews, and there we anticipating at some further area there where firms may be subject to a skill person review, or to that effect, actually having to find out their station to make sure that in fact that they have, for instance, got delegated authorities correct.

Regulators are keen to oversea individuals, as I've mentioned. One important point here is actually consolidation of committees. This has been a fairly positive step. It intended to and enabled them to perhaps remove talking shops or foreigns that weren't genuine committees and actually reduce some time there as well.

But my last point here, in a sense, is on the final bullet point. First, keeping a steady state of preparedness. Being ready to send, to respond to the FCA if they're looking for requests of information as they begin to up their game within supervision.

Turning to the next slide, please, if we can move on to fit and proper assessments. What we've been saying, again, only from the firm to get it right, hence things have taking perhaps longer to get through than previous [inaudible 00:41:47]. I think as you look down the bullet there, if I could just highlight the use of a people or F&P Committee to consider the evidence. This is again to ensure consistency of approach important to ensure that the escalation and communication process is rapid. The escalation of an issue and reporting it is a way in which the regulator is affecting culture within a firm.

Importantly again now, where there is an issue, it's not letting that issue stagnate. The embolden phrase at the bottom there, "A firm must take 'reasonable care'." Back to reasonableness again, that no individual is certified without being devotedly fit and proper. The next slide please.

Again, some typical queries that we've been talking about. We've touched on some of these already. This is just to give you a sort of overview, population identification for senior managers, as well as for certified individuals has been sometimes a bit of a challenge, particularly around the seniority of the senior manager. I know a few firms that have had some pushback there where the regulators have not thought that the individual is sufficiently senior to take that role on. In addition to that role sharing, the regulators not particularly too keen on role sharing, and importantly that a role is going to be shared, it's making sure that is very clearly articulated.

Moving down the bullet, I've touched on a couple of those, but adopting a handover process across the firm has been seen as good practice. On performance management personal characteristics, this is where firms are perhaps going to look to get at their fifth proper assessment process and introduce some more testing, psychometric testing, particularly where an individual is hold down a supervisory or managerial role. You can move to the next slide, please.

I've covered actually most of the these issues. I wanted to just give you a summary slide here in terms of expectations, that it links back to the regulatory references area as well in terms of understanding just how much time these issues can take, hence the reason why having some form of people committee is absolutely critical.

 

This webinar was co-hosted with Eversheds-Sutherland

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