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.
The ongoing advice charge conundrum
Paul Jay Compliance 2018, Conduct, FCA, MiFID
A high proportion of advice firms operate a largely recurring income model and with this comes the obligation to conduct client reviews. This is a subject that raises its head frequently with firms, especially with Consumer Duty considerations. Reviews are nothing new but when MiFID II came into effect on 3rd January 2018 it introduced […]