Business Risk Awareness Workshops: Useful Feedback

Following the recent batch of FCA BRA workshops, we have gathered some useful feedback from clients.

  • Business plans. Even though not a rule requirement, the FCA expect to see one. In truth, most firms don’t have one. It is a question on our audit that firms often fail. Please note the FCA stance.
  • Internal file checks. Again, this is something we strongly recommend. There should be a balance of internal and external checks.
  • Regular board meetings. These should be documented and should review what’s happened using management information, but should also look forward and anticipate (proactive planning).
  • Checklists. They like them.
  • Reliance on compliance consultants. As we always make clear, we are here to advise and assist but ultimately, regulatory responsibility lies with the regulated firm. Don’t trust any compliance consultancy that tells you otherwise.
  • Management Information. As we’ve been saying for a very long time, MI is very important. The MI review should be documented and should focus on areas of risk.
  • Dominant person risk. Is there someone in a lofty position that won’t listen or makes all the decisions?
  • Resource risk. Needs managing. Is compliance, for example, allocated sufficient resource.
  • Clear reporting lines. Important.
  • Data protection. The FCA suggests that files should be stored in fire proof, locked cabinets, not on show.

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

Our View

The good news is that if firms follow our advice, there will be no surprises from the FCA workshops.

Action Required By You

If you are subject to a face-to-face review, the FCA will want to understand your business model, how controls are managed, how MI is used, how you manage risks, the firm’s overall sustainability and financial stability.

You should therefore be able to clearly articulate all of these issues if asked.

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About the Author

Steve is an ATEB Director and has a deep understanding of all matter regulatory, built up over his 30 years + in the industry. With a training background and a technical brain, he overseas numerous complex projects and client implementation work.

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