During a recent workshop, the FCA commented on SM&CR training. They do not believe that some e-learning or short generic training meets their requirements.
We believe that this is primarily a reference to the need for all staff to understand the intention of the SM&CR to move firms to a culture of accountability at all levels. Accordingly, Conduct Rules training should include the opportunity for individuals to identify how these apply to their own organisation and, in particular, to their role within the organisation.
Model behaviour
Alistair MacDougall Compliance Drawdown, EBI, FCA, ML, PI, Switch
The advent of Consumer Duty has catalysed a lot of focus on fair value, or at least a lot of chat. Anecdotal evidence would appear to suggest that many firms may not have made any material changes to their charging structures. However, a recent survey by Schroders gave rise to a headline in the financial […]