Our starting point to FSA compliance was a GISC audit in October 2002. This identified some shortcomings and forced us to produce a compliance plan.
Early on, we identified from the health-check a ...
Our starting point to FSA compliance was a GISC audit in October 2002. This identified some shortcomings and forced us to produce a compliance plan.
Early on, we identified from the health-check and consultation papers that the main areas we needed to concentrate on were systems and controls, training and competency, and prudential requirements.
Consequently, we have reviewed, or are in the process of reviewing:
Importantly, our staff are being involved wherever possible, for example, in documenting our procedures, and helping to identify skills and competencies at job roles.
From the start it was important to get the board on side and give them an insight into what we needed to do and what their responsibilities were. Fortunately for us this was not a problem.
We have now set up a plan for the "run-in" to application for authorisation. We hold regular fortnightly compliance meetings with the managing director, with whom the plan for authorisation is reviewed. This keeps him up to speed with what is happening with the near final rules. We also maintain a link with compliance consultants to provide us with the reassurance that what we are doing is right.
Going forward, there are a number of areas that concern us. First, we do some wholesaling, so we want to know whether the people we deal with are seeking to obtain authorisation in January 2005 and what their chances are. If they fail, we will have to contact insureds quickly.
The second concern is time. We need to have everything in place by the time we apply for authorisation - or at least have a detailed plan in place that shows that we will be compliant.
Finally, we will have to reissue contracts for appointed representatives, appointed introducers and sub-agents. It would be useful for there to be a standard set of wordings for the industry.
Overall, I feel the FSA is trying hard to get it right and it has listened to the market - although it will not please everyone.
Recently, I was asked what the FSA was going to do to inform the general public about regulation and what it will mean for them. Very few members of the public know of the FSA let alone what it does and how it will affect them.
