Now is the time for intermediaries to be preparing for the start of regulation. It will not be sufficient to assume, just because they have submitted their application, or indeed received their 'minded to authorise' letter, that the job is done. A prudent approach in this preparatory process might be to adopt a regulatory checklist. The following points might help.

  • Senior management systems and controls - organisation charts, reporting structures, compliance breach log and report, regulatory risk log, audit checklist, business plan, business continuity plan, risk assessment and whistle blowing procedure

  • Prudential - solvency margin, eligible assets, capital, professional indemnity insurance, trust account creation

  • Training and competence - job descriptions, competency listings, recruitment procedure and checklist, induction programme, appraisal procedures, training and development plans and individual training logs

  • Redress - complaints procedure (both for internal use and for customer use), complaint log, complaint report and procedure to identify and then remedy

  • Regulatory processes - data reporting, regulatory aspects of acquisitions, auditors (if appropriate)

  • Business practice - intermediaries will need to address their day-to-day conduct of business obligations in respect of areas like inducements, advertising, terms of business, status disclosure, demands and needs statements, product disclosure, cancellation rights, renewals and claims handling.

  • Steve White is regulation and compliance manager at Biba

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