Having established that neither Willis nor network members wanted to become appointed representatives, Willis focused on consulting members to define the services required and a mechanism for delivery.

The first step was the creation of the network FSA steering group, chaired by Willis, but principally comprising members. Due to the critical nature of the decisions being made by the group, it was essential for it to have senior representation from members. It was also important to have a broad geographical reach. Participation from all three regions in England and Wales was secured at principal level.

This structure is typical of the inclusive approach taken by the network. It can respond to members' needs by involving them in the process and not simply unilaterally distributing solutions without consultation.

The steering group's objective was to collate feedback from the consultation process and define

the precise requirements of the membership. These were:

  • An IT-based training programme
  • A well resourced and knowledgeable independent consultant
  • Consultant sign-off of the generic network manual
  • A comprehensive training facility for members
  • A training programme for members to act as auditors
  • The ability to keep the network updated on regulatory changes.

    A key part of negotiations with all external providers is to secure their services for the network as a single buying source, aggregating the network's purchasing power.

    With regard to IT training, in the first quarter of 2003, the CII's Ed. online compliance and competency system (CCS) was recommended to the network.

    This recommendation ensured all staff, as a minimum, had the foundations of compliance covered, providing evidence of learning and understanding in basic subjects. These included agency law, data protection and general regulatory awareness.

    Members now have the option to migrate to Broker-Assess with full data conversion.

    We believe it is important that members can demonstrate to the FSA that they have not by-passed the due process, and that they have committed to a compliance culture by creating their own manual and not buying an off-the-shelf set of procedures.

    To deliver this, a working group was created to compile a generic compliance manual drawing from a wide range of expertise from within the network.

    Knowledge sharing is another characteristic of the network, and this enabled successful completion of the manual early in second quarter 2003.

    Members are now applying the procedures in the manual to their own business. In addition, many are receiving external audits and guidance as well as receiving ad hoc support from the steering group. .

  • Mark Radburn is managing director of Willis Commercial Network