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.
Principals and Appointed Representatives – action needed
Alistair MacDougall Compliance 2016, FCA, PI
Following recent FCA investigations that resulted in a Dear CEO letter, firms that have Appointed Representatives need to review the adequacy their governance and supervision.