Compliance tip

Compliance tip: How to drive cultural change

The FCA’s recent discussion paper, DP18/2: Transforming Culture in Financial Services, focused heavily on how to drive cultural change within an organisation. A number of the paper’s contributors highlight that focusing solely on senior management behaviour and the ‘tone from the top’ overlooks the complexity of organisational culture and the role all employees have in […]

Compliance tip: Do you need to opt out of Mifid II?

There are many reasons why a firm might wish to amend its status from Exempt CAD to Article 3. Exempt CAD firms have usually opted into Mifid in order to passport their investment services into another EU member state, or to enable them to transmit orders in unregulated collective investment schemes to non-Mifid firms. Article […]

Compliance tip: Five steps to GDPR compliance

With the General Data Protection Regulation fast approaching, firms should be turning their attention to the necessary updates to policies, procedures and business practices required for ongoing compliance. This five-step framework will help guide you through the transition. Identify your data: It is essential firms have a clear understanding of the types of data they […]

Compliance tip: Meeting FCA expectations around culture

The FCA’s focus on firms’ culture and conduct is set to intensify as it begins its preparations to roll out the Senior Managers and Certification Regime. The consultation papers released in December provide a good indication of the regulator’s direction of travel, with culture, particularly the tone from the top, being a key consideration. Below […]

Compliance tip: Reducing Gabriel completion stress

The deadline is looming for many firms’ Gabriel reporting. Parts of the return are easier to fill in – training and competence, complaints, PI policy details, for example. But the accounting and capital adequacy sections need more preparation, as you will generally need to delve into management information or consult your accountant. A lot of […]

Compliance tip: How to deal with regulatory change

Regulatory change can leave firms struggling to keep pace and maintain effective compliance. To ensure a successful and sustainable response to regulatory change, firms should consider the following areas. Culture Culture is the foundation of any business and if a firm’s culture is not sufficiently client-focused it will be unable to consistently deliver the right […]

Compliance tip: Key changes to comply with Mifid II

The Insurance Distribution Directive, General Data Protection Regulation and Mifid II all impact how firms interact with clients, leading to necessary changes to client agreements. Here we consider the main alterations that will need to have been made to comply with Mifid II. It has always been necessary to describe the service to be received […]

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Mifid II checklist: Are you ready?

The implementation date for Mifid II (3 January) is rapidly approaching, with seasonal celebrations reducing preparation time further. Now is the time to conduct a self-assessment to establish your firm’s state of readiness. Mifid II affects investment advice and discretionary management firms differently, so your actions will be tailored to your firm type. In addition, advice […]

Phil Deeks

Compliance tip: The right training to support vulnerable customers

The FCA’s focus on vulnerable customers shows no sign of abating, with its recently published Future Approach to Customers once again highlighting its expectations firms treat them fairly by providing a flexible and tailored response. But just as there is no ‘”one size fits all” definition of vulnerability, there is also no single way to […]

Compliance tip: An important reminder about PII

From 23 February, the Insurance Distribution Directive will set new minimum levels of professional indemnity insurance for firms involved in the distribution of insurance products. This affects all firms advising on, arranging or managing non-investment insurance contracts (pure protection contracts and life policies such as long-term insurance contracts and annuities), insurance-based investment products and general […]

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Compliance tip: Mifid II transaction reporting and legal entity identifiers

Transaction reporting Transaction reporting is the reporting of information about trades in reportable financial instruments, such as shares, ETFs, VCTs, investment trusts and structured products. Reporting covers purchases, sales and modifications of reportable instruments. Mifid II proposes important changes to these obligations which will potentially affect all investment firms. Some exemptions will apply. For instance, […]