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New systems and controls requirements came into effect on 1 April 2009 to the UK Regulator, The Financial Services Authoritys (FSA), Senior Management Arrangements, Systems and Controls sourcebook (SYSC). The changes will mainly affect mortgage and insurance intermediaries and IFAs. Currently, these firms are only subject to SYSC 2 (senior management arrangements) and SYSC 3 (systems and controls). From 1 April 2009, the FSA applied the common platform term involving SYSC chapters 4 to 10 to these firms. This will mean some new requirements, such as outsourcing and management of conflicts of interests and risk assessment and control.

Under SYSC all staff within the firm must demonstrate they have the skills, knowledge and expertise to undertake their role – in other words, a robust Tamp;C Scheme or plan which is followed and fully documented. All relevant staff must be able to demonstrate that they are competent in the work that they undertake and that they are fully aware of the firms procedures and rules, namely; the compliance manual and T&C Scheme. Whilst some insurance and mortgage firms uwill still not need/u to have a specific CF 10 (Compliance Officer), the FSA ask these firms to consider (under SYSC) how their compliance responsibilities are delegated and supervised. Under the rule changes, all Directors of a firm will be jointly responsible for the running and compliance of the firm, not just those persons delegated with the compliance and Money Laundering responsibilities.

CEI Compliance is currently offering a special rate for reviews of UK smaller firms and details can be obtained by email at offerG6@cei-compliance-limited.co.uk

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