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.
Advising non-UK clients
Alistair MacDougall Compliance Conduct, EEA, email, EU, FCA, MiFID, passport, PI, vulnerable
Despite the fact that the UK ceased to be a member of the EU/EEA almost a year ago, we are still asked for advice around how a UK firm can take on a new non-UK client or continue to deal with such clients that the firm had pre-BREXIT. We have written before about the general […]