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.
Conduct Rules Breaches – follow up
Huw Reynolds Compliance Conduct, FCA, Pension, Senior Manager, Update
We wrote recently about the Conduct Rules and, in particular, breaches and notifications . See here. This article is intended to clarify some of the grey around COCON breaches. All of the following is taken from Policy Statement PS 18-14. When is disciplinary action required? When and how a firm decides to undertake disciplinary action […]