The legal cut over from the FSA to the FCA is due to happen on 1 March 2013. This mean that firm’s have a window of opportunity to get on the front foot with the FCA.
TOP TIP: Consider updating your ‘TCF Strategy’ and re-naming it, ‘Conduct Risk Management Framework’. Record the fact that you are doing this in your board minutes. The FCA expects the board to be engaged in the conduct risk agenda and will take comfort from the fact that they are keeping pace with regulatory change.
TOP TIP: Arrange a workshop to identify: ‘current issues’, ‘emerging risks’ and ‘potential concerns’ that have a potential impact on your business.
TOP TIP: Communicate with staff at all levels on a regular basis to ensure consistency of message. Think about e-Learning. The FCA will want to understand how a firms’ culture, governance and controls translate to all levels of the business, not just senior management.
TOP TIP: Remember to take account of the FCAs’ regulatory reach. Don’t fall into the trap of thinking that wholesale customers are excluded. You need to consider the end user. For example, where your customers are trustees but the ultimate beneficiaries are individuals.
To find out how we can help, contact Peter Sibthorpe on 07884003106.