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.
Data protection for joint parties
Alistair MacDougall Compliance 2018, Data Protection Act, GDPR, ML
Take care not to be caught out if the client provides details of another person.