Regulation and legislation is constantly changing and it can be hard to keep up to date. Larger firms usually have dedicated compliance teams, small to medium sized business often do not have this luxury and there are not enough hours in a day to focus on all aspects of your business.
Regularly reviewing your processes can often be overlooked but this can potentially be a risk to your business in terms of enforcement action, fines, or compensating existing clients.
Demonstrating effective governance arrangements
A compliance health check can identify where there are gaps in your existing process and procedures and also provide solutions that are appropriate to your business model. The regulator expects firms to have effective governance arrangements in place.
Prior to the visit
ComplyMe will issue a request for information eight weeks prior to the visit (please note receipt of all requested information will be required at least four weeks prior to the visit). You will be issued a user name and password so you can download the requested documents in a secure way.
Summary of Information
A summary of the types of documents/information we may request is listed below. This will enable us to identify areas of focus for the visit.
- Copy of your Compliance Manual
- Company Structure
- New Business Register
- Centralised Investment Proposition/Best Advice Panel for products/Investment methodology
- Copy of Fact Find/or Client Information Summary
- 5 client files per consultant
- Terms of Business Letter/Engagement Letter
- Client Service Levels (segmentation of clients)
- A percentage breakdown of business (investment/pension/mortgage/protection/trusts)
- Financial Promotions register
- T&C Scheme (including completed observation and meeting forms for T&C purposes)
- TCF outcomes/overview/evidence that TCF is embedded within the firm
- CPD Register for all staff
- Complaint Register
- Anti-Money Laundering and Financial Crime procedures
- Data Protection Act and Registration process (evidence of annual testing)
- Gifts & hospitality register (if used)
- Professional Indemnity Insurance
Conclusion of visit
At the end of ‘the visit’ to your offices, we will discuss our findings and a Compliance Health Check report will follow, outlining our findings and will detail recommended actions in different areas using a ‘RAG’ system (Red, Amber and Green).
RED - Priority areas that are recommended to be addressed immediately
AMBER - Areas that require improvement/updating
GREEN - No identified areas of concern or improvement required at this time.
How we can help
ComplyMe will provide a personalised service and provide solutions that are appropriate to your business model. You may wish to have a Health Check on your overall business, or just on one aspect such as your existing investment proposition, we can adapt our service to suit your needs. ComplyMe can also offer an ongoing monitoring service once a year to ensure that all areas remain up to date and relevant, giving you peace of mind and allowing you to concentrate on your clients.