The FCA has issued guidance for firms in relation to processes for handling paper and post during the COVID-19 emergency. Firms should read the guidance. The key messages are:
- The FCA understand that some processes will not be able to be complied with currently. Where that is the case, firms need to notify the FCA.
- Firms should take reasonable steps to mitigate the impact of any non-compliance with normal required processes and timescales.
- Firms should ensure they collect post delivered to the normal place of business as regularly as possible so it can be dealt with as appropriate.
- Firms should take steps to inform clients of current arrangements and delays that might occur, for example through the firm’s website or by email, and update the information as required.
- Cheques and transactions that cannot be processed should be confirmed to clients as soon as possible and any funds returned.
- The needs of vulnerable customers and others who might not be able to access online services should be addressed.



MiFID II – Aggregated costs disclosure
Alistair MacDougall Compliance 2017, 2018, 2019, MiFID, PI
This new requirement is posing some questions about how it can best be implemented. We think that firms should wait until the mechanisms in the market place are a little clearer.