Suitability Reports remain a focus of the Financial Conduct Authority (FCA) and they have stated that they plan to visit a number of firms at the end of the year to see if firms have taken their findings on board and made improvements where appropriate. The FCA expect firms to regularly undertake file reviews to demonstrate their management and controls.
File reviewing can be time consuming but this will not be an acceptable excuse if the FCA identifies shortcomings in the visit that could have been identified earlier. Proactively reviewing your business is preferable to a fine or additional regulatory attention.
You may have areas of advice where you think a review would be beneficial. There have been many changes in recent times in terms of regulatory requirements and legislation, such as Pension Freedoms.
A sample of file reviews could demonstrate that your consultants have got to grips with all the changes or identify training needs. Undertaking file reviews may also identify any weaknesses in your current processes such as Money Laundering/disclosure of remuneration etc.
You may wish to interrogate an individual adviser’s work and adherence to your internal processes. In addition, file reviews in conjunction with other management information (e.g. complaint data, Key Performance Indicators) can provide you with a clear overall picture, providing firms with the assurance that their clients are receiving good quality advice and that you have the client best interests at the heart of your business.
How we can help
ComplyMe can undertake remote file checking on a regular and/or on an ad-hoc basis. We will provide a report which will highlight good practice and, where appropriate, areas requiring improvement and/or training. We will discuss the findings with you and if required can assist you in these areas requiring improvement and provide solutions appropriate to your business model.