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.



FG 21/3 – client objectives
Alistair MacDougall Compliance Drawdown, FCA, ML, Pension, Pension Transfer, PI, transfer
Following on from our previous articles on FG21/3, we will look today at another of the interesting areas covered by the guidance. It goes without saying that the guidance itself is helpful, reiterating and emphasising previous rules and guidance and clarifying some areas that were arguably fuzzy before. However, as well as the actual content, […]