Policy Statement 08/9, which was published by the FSA last Autumn, requires mortgage and GI Intermediaries to consider their approach to where MiFID firms have already had to strengthen their internal policies since November 2007.
“Organisational systems and controls – extending the common platform” is the policy statement title and has the deadline for implementation by non-MiFID firms by the end of April 2009. This involves reviewing compliance, internal audit, risk and outsourcing audit processes.
Telos Solutions project director Richard Farr says: “Many firms may not have to change anything after their audit in regard to PS08/9, but to figure that out takes time. All firms need to read PS08/9 to work out whether they need to add policies to their compliance systems.
“The problem is this PS08/9 is unengaging, it’s a stealth issue. But the FSA will bring this up and if a firm gets an Arrow visits and the firms will have to eloquently explain their position regarding it.
“It’s foresight on the FSA’s part, a tightening of controls. But how many intermediaries are sure they are ready? This issue is real, it’s present and advisers are running out of time to get ready for PS08/9.”