Our compliance support activities range from providing ad hoc assistance to in house compliance departments to the provision of a full service for smaller firms to assist management to discharge their compliance responsibilities effectively while relieving them as far as possible from the burden of day to day compliance work. A common feature of all our compliance support arrangements is our partnership approach; we bring the compliance experience, knowledge and resources, our clients bring the detailed sectoral knowledge, set the compliance culture and make the decisions.
Please scroll down to see the range of services we offer, or use the links on the left to jump straight to a particular service.
Ad hoc assistance varies enormously in range and scope, depending entirely on what the client wants. You can see some examples of more significant ad hoc projects on the reviews and special projects page.
For smaller firms that need a degree of continuing hands-on support with routine compliance activities we offer our "Basic service". This combines our monthly tailored regulatory update ("Bespoke") with up to 5 hours per quarter consultancy support and assistance for a flat fee, with additional support available on an hourly basis if required.
The support allowance can be used for any purpose; typically it might extend to liaising with the FSA on the client's behalf, preparing and arranging submission of regulatory returns, or undertaking an element of compliance monitoring, as well as dealing with miscellaneous queries as they arise.
For other requirements we can tailor a package of ongoing support services according to your needs. Many clients who deal themselves with most routine day-to-day compliance tasks like to take our Bespoke update service and then seek ad hoc advice and assistance as and when particular issues or tasks arise. We are very happy to set up arrangements of this kind. One of their benefits is that we can keep you advised of particular regulatory developments and points to note, based on our knowledge of your business, and help you address any issues which arise quickly and effectively.
We are frequently asked for advice on capital adequacy and financial returns. The rules are complex and different rules apply to different categories of regulated firm. As well as advising on the application of the rules we can undertake financial modelling to determine whether or not a firm will continue to meet its capital requirements in the event of changes in revenue, costs, debt/equity ratios or other external factors. We can also prepare returns, working from firms' management accounts, and arrange submission to the FSA on behalf of the firm concerned. In the event that a firm does breach its capital (or other) requirements, we can advise on remedial action and the necessary disclosures to the FSA.
The rules on capital adequacy for banks, building societies and investment firms have been radically overhauled as a result of the Capital Requirements Directive (CRD), and new requirements apply from 2007. The reporting requirements are also changing. We can assist you with implementing this important transition – for further information see the CRD section in our "Briefings" pages.
Proper documentation – written procedures, manuals and guidance notes - is an essential part of effective compliance. We believe that if such material is to serve its purpose effectively, it must be written to fit the particular needs of the business concerned and the people who work in it. For example, a secondary insurance intermediary whose principal business is not in financial services at all is likely to need very different procedures from a primary insurance broker, even though their scope of permission may well be identical. We have extensive experience in drafting such fit-for-purpose compliance-related documentation.
We can also review and advise on customer-facing documentation such as terms of business agreements, Initial Disclosure Documents and policy summaries, in the light of the requirements for such material to be "fair, clear and not misleading".
A key element of ongoing compliance support is the provision of periodic compliance monitoring. The FSA expects regulated firms to establish procedures to monitor compliance with FSA rules. An element of external compliance monitoring can help satisfy this requirement. We have developed a risk based compliance monitoring methodology which is both flexible and comprehensive. It can easily be tailored to the requirements of an individual client in terms of both scope and frequency.
FSA puts out a vast amount of information each month on its website – changes to the Handbook, consultation and discussion papers, feedback on supervisory issues, updates on its thematic priorities and so on. Firms need to keep up with the issues which affect them – but it can often take time to work out which announcements really matter and which are the key points the firm needs to focus on.
We provide help with this through our "Bespoke" service. As its name suggests this service is tailored to the subscribing firm. Every month we review the rule changes and other material issued by the FSA (and other relevant agencies such as the Treasury and the JMLSG) and advise the firm concerned of the items which are specifically relevant to it, either for action or as important background information. We will add appropriate commentary where necessary, and will if required include reminders about approaching FSA returns deadlines.
"Bespoke" is an integral part of many of our ongoing support arrangements, but is also available on a stand-alone subscription basis if required. Please contact us for further details.
You can find a sample (albeit untailored) copy of "Bespoke" here.
While the provisions of the FSA's Training and Competence Sourcebook now apply only to retail business, all firms need to ensure that their employees are appropriately competent. We regularly assist firms with the implementation of Training and Competence requirements both from a procedural perspective and by delivering training sessions.
We can offer a wide range of regulatory, compliance and money laundering related training. Training services are tailored to individual company needs and are designed to:
- assist firms in educating staff in relation to compliance and regulatory matters;
- assist firms in meeting their regulatory requirements under the Money Laundering Regulations 2003 and the FSA's Systems and Controls Sourcebook;
- brief senior management on their regulatory responsibilities and the new regimes;
- help firms to meet their compliance training obligations.