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FCA Systems and Controls

Compliance Documentation & Manuals

Your firms compliance Policies, Procedures, logs and any additional Documentation are known as a Compliance Manuals. Your Compliance Manual is an essential part of your firms’ compliance framework ensuring you are meeting the requirements not only set by the FCA but your internal standards.

Compliance Monitoring Plan

A Compliance Monitoring Plan (CMP) is used to identify, assess and react to potential and actual compliance breaches. It is a fundamental document which is integral to the FCA application and post-authorisation process. A CMP must account for key compliance risks to a business and outline how a firm plans to mitigate for these risks and who will be responsible for any actions taken to mitigate risks. For example, call monitoring, a standard method for compliance monitoring, will help to identify whether any compliance requirements are being met. If they are not being met, a firm is then able to act upon this to ensure future breaches are avoided. A CMP is a working document that should be amended and updated to reflect any newly identified risks or to recalibrate current risks and responsibilities.

Scott Robert is well versed when it comes to the creation of Compliance Monitoring Plans. Due to our demonstrable knowledge and expertise we are able to draft a complete and comprehensive CMP that is tailored to your firm and any proposed FCA activity.

Policies and Procedures

By applying to and being authorised by the FCA, a firm will be expected to have established effective policies and procedures that enable a firm to comply with relevant requirements. In some cases, i.e. dependant on an the proposed FCA activity and circumstances, applicants must submit a full suite of policies and procedures to the FCA as part of the application process. For others, the FCA may simply request these once an application has been submitted or may not request them at all. If an applicant is unable to demonstrate that they have effective policies and procedures, when requested by the FCA, an application for authorisation may be refused.

It is therefore essential that Policies and Procedures are drafted and utilised as an authorised firm. Scott Robert has developed Policies and Procedures to enable firms to satisfy these requirements. Firms are reminded that Policies and Procedures should be maintained, updated or even created where new processes are established or where a firm becomes subject to new requirements e.g. as has been the case for many firms seeking to comply with the Senior Managers & Certification Regime which was introduced for all FCA regulated firms towards the end of 2019.

Registers and Logs

Firms must maintain adequate records. This means that efforts and actions undertaken to comply with relevant rules and requirements must be recorded. In some cases, registers and logs will serve as a means for documenting compliance breaches or the satisfaction of certain procedures as may be the case with a register that indicates completion of various monitoring requirements or registers that log breaches following completion of various monitoring requirements.

As part if an applicant’s authorisation process or for those currently authorised, Scott Robert can provide relevant Registers and Logs that should be used to comply with this requirement i.e. to maintain adequate records.

How Can Scott Robert Help?

If you are seeking to apply to the FCA, Scott Robert can work with you throughout the course of the application process. This will include the provision of all Compliance Documentation and regulatory documentation that is otherwise required. For more information on how we can help with the authorisation process please see our FCA authorisation page

For those who are navigating through the FCA application process but need only to establish constructive and effective policies and procedures, Scott Robert will seek to identify the documentation required that authorised firm would benefit firm and produce these in consideration of those requirements. For many authorised firms Scott Robert has produced a suite of documentation to comply with the Senior Managers & Certification Regime.

Scott Robert can review an authorised or applicant firm’s current or proposed compliance documentation and provide a gap analysis or advice and guidance regarding any proposed amendments.

Why Choose Scott Robert?

Scott Robert has been supporting firms through the FCA compliance process since 2008. In that time, we have helped hundreds of businesses to successfully gain and retain FCA authorisation.

We employ a team of compliance consultants who are both highly experienced and expertly skilled. We specialise in providing our clients with solutions to often complex regulatory requirements and compliance needs.

Our industry insight and comfort with compliance enables our team to support you to the fullest extent possible, helping to develop your business model and compliance.

Conducting regulated activities without the correct authorisation is a criminal offence, speak to one of our experts today for confidential and no obligation advice FCA authorisation.

Interested in learning more about how you get FCA authorisation? Call us today by calling 0161 914 5727 to find out more.

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FCA Systems and Controls

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