We have now enjoyed exhibiting and speaking on RegTech at 6 of the 26 Personal Finance Society (PFS) Regional events. They seem to attract high quality delegates from the retail investment advice sector and are extremely well attended throughout each day
The main themes and questions we have fielded when it comes to our interaction on regulation readiness seem to spread across:- SM&CR: HOW to implement this all-encompassing regime not to what it is seems to be the key concern. This is where the banks struggled in 2016, ensuring Business as Usual whilst running a SM&CR implementation project was a challenge, some employed the wrong staff or technology that didn’t fit.
So firms now need to ensure they have a robust system and framework in places across the 3 parts to the regime:
-Identifying Senior Managers and ensuring their Prescribed Responsibilities are correctly allocated, they know their delegation responsibilities and who has overall responsibility
-Building lifecycle strategies for Certification and Conduct rule implementation. This will help ensure firms take a holistic approach to implementing both and overcoming challenges across identifying who are classed as ‘Information Givers’ and how Conduct Rule breaches are handled using the reasonable steps
- Risk management: What strategy and resources should be taken to ensure regulatory risks such as ensuring MiFID II’s suitability and disclosure rules are met. With the FCA conducting another advice suitability review later this year, firms should ideally follow the FCA’s 5 conduct risk questions across:
- Identifying the risks at hand
- Empowering individuals to manage those risks
- Employing mechanisms to improve risk management
- Ensuring robust strategic oversight
- Assessing activities that could undermine good risk management
3. Compliance costs: How to put a stop to this hard Professional Indemnity market by showcasing good professional practice management across the business.
These three areas alone are enough to keep firms busy over the final 2 quarters of the year. Indeed firms should reach out for quality solutions to ensure they outsource effectively to ensure a ‘four eyes’ approach to both areas.
We have our next SM&CR free webinar coming up Monday 8thJuly 11am; you can sign up below. Plus we’re running more SM&CR Unwrapped workshops through Q3/4 so watch out for these as they provide practical planning points and a comprehensive SM&CR Implementation pack included 8 guides/reports, webinars and a project plan.
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