Keeping Your Compliance Essentials In One Manual
Why Should I need a Compliance Manual? For anyone who has been in the UK financial services industry for any more than a year, will know that one of the first documents that they have to read and attest to having done so, is the Company Compliance Manual.
Often Compliance Manuals can be used to document the sales process for adviser's to follow including, for example, transaction only clients (there is no execution only anymore unless it is a self-trade) and clear distinction for specific procedures and, for example when to assess a client for appropriateness when they refuse to provide sufficient details for suitability.
A recent area that needs greater definition is the Conduct Risk and how the firm has deemed it applies to them.
Although this is not a regulatory requirement, it is a regulatory expectation as there are a number of elements that the regulators not only expect to be documented, but also somewhere that explains the rationale behind the way that company's manager their risks. This would clearly be best summarised in a regulatory Operational or Compliance Manual.
Whereas we do not suggest you fill your Compliance Manual with processes it is a valuable place to store certain policies such as the Data Protection Act, Bribery Act, Outsourcing Policy and Whistleblowing protocols as well as pointing to other documents that are more likely to need constant updating such as the Anti-money Laundering and Terrorist Financing or even areas such as your Approved Persons Policy or changes to the Mortgage Sales Policy post MMR (and possibly additional changes from Euroland in the future after Brexit).
The content of your Compliance Manual has to be specific, relevant and accurate as well as reader friendly. We do not update the manual and dictate to you what you should update (as it may not be relevant or pertinent to your business model) and therefore we do not charge update fees. We do not sit down and write your manual from scratch (an exercise that is expensive in both cost and management time).
Once purchased, the Compliance Manual is yours to updated and amended as you see fit, updating and amending what you need to on issues and areas that you feel are important.
We do not feel that keeping your manual updated year on year is beneficial to you as the FCA and PRA consider that The key to an effective the Compliance Manual is that it must be bespoke to the firm.And don't forget, our Template Compliance Manual has been bought by IFAs, Private Banks, GI Brokers, Payment Providers, Portfolio and Asset Managers, stockbrokers (execution only and advisory), some foreign company's with UK interests but mainly domestic small to medium sized firms, including local council lending initiatives! The contents that are covered in the Compliance Manual covered (alphabetically) are: (*Full Version Only) Advertising for New Business Anti-Money Laundering Breaches, Discipline & Enforcement Bribery, Facilitation and Unethical Payments* Business Continuity* Client classification* Company introduction and areas of business Company’s compliance structure Complaints handling & procedure* Complaints Sample Logs (General, EONWD, RFCs)* Conduct Risk Conflicts of Interest Controlled Functions and Governance Customer Assets* Data Protection Data Protection & Employees Rights Dealing with Customers FCA/PRA Principles for Business Financial Promotions High Level Regulatory Requirements Inducements/Gifts and Entertaining* Introduction and responsibilities of staff Market Abuse & Insider Dealing* Notifications to the FCA/PRA Outsourcing Principles & Code of Practice for Approved Persons Record Keeping Regulatory environment and Scope of permissions overview Remuneration Risk assessment Senior Management Systems and Controls Senior Staff/Management listing Specific Permissions for company Table of Contents Terms of Business* Training & Competence Treating Customers Fairly (TCF) – Overview* Treating Customers Fairly (TCF) – Application* Version Control log* Whistle-blowing Plus an extra section with hyperlinks to current rules and legislation, categorised for ease of your reference Our Template Compliance Manual has over 90 pages of areas that are best concisely explained or stated in this central reference point in a logical and cumulative layout. You get a Fully Customisable Document with an editable Cover Sheet and Fully Editable Contents with a list of specific highlighted areas for you to make amendments appropriate to your company setup. To anyone with a modicum of MS Word skill, the Table Of Contents is easily updateable with just three clicks of your mouse. Our Compliance Manual is written in simple English that enables your Senior management as well as Advisers and Administrative Staff to understand what the FCA rules mean in practice and how you apply them to achieve and maintain compliance. If You Have Seen The Rest Now Get The Best!
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