What FCA consultants check in your policies

There are 2 things that an FCA Compliance Consultant will check when reviewing your firm’s compliance documentation.

Conflicts of Interest Policy

This type of generic text will be picked up straight away by FCA Compliance Consultants as they read through your policies. The Conflicts of Interest Policy should clearly outline the conflicts that exist within your business model and how they are managed on an on-going basis.

Complaints Handling Policy

A review of your firm’s Complaints Policy will identify whether your policy maps against the eight week timescale for handling complaints. Furthermore, it will confirm whether reference to the Financial Ombudsman Service (FOS) and the method of referral is adequately outlined.

Financial Promotions Policy

Financial Promotions Policy – approval for financial promotions to be issued by certain employees within the firm, with written checklists to approve financial promotions (as opposed to stating that they will be reviewed).

SM&CR Responsibilities Policy

Each Senior Manager (as individually named in the Roles) should have a separate document containing a signed Statement of Responsibilities (completed on a form – as a check-box list). These need to be current and to reflect individual responsibilities (as opposed to identical copies for multiple individuals).

AML and Financial Crime Policy

Open-ended wording in the Data Retention area such as “records will be kept as required” will also be highlighted. g. 6 years for client files, as applicable to most FCA-regulated businesses and their corresponding records).

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Data Retention Policy

Open-ended wording such as “records will be kept as required” will be highlighted by compliance reviewers. Instead, your Data Retention Policy must include specific time periods for the destruction of each type of document. For example, for the retention of client documents, six years is the normal period for retention of most documents that relate to FCA-regulated business.

By completing these checklists before contacting outside help for a review of your policies and procedures you can save a lot of time and money.