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.



Ukraine – 10% drop reporting
Alistair MacDougall Compliance 2020, 2022, COVID-19, FCA, Update
The current hostilities in Ukraine have caused significant market drops and may continue to do so. Accordingly, a reminder about the 10% drop reporting requirements is timely. Readers will recall the early days of the Covid pandemic in 2020 caused a period of market volatility that necessitated issue of 10% drop notifications to clients. […]