Compliance Audits

Evidence Compliance to the regulator by commissioning a review by our qualified audit team. 

In auditing terms, we often hear the phrase 3 lines of defense, what does this mean?

  1. Can you demonstrate strong management control and good governance? The culture of a firm is dictated from the top,
  2. Can you demonstrate that the day to day carrying out of documented policies and procedures is being done compliantly?
  3. The third line is usually an internal audit which is likely to be your Compliance Monitoring Programme (CMP). But how do you know that the activities recorded on the CMP are being carried out?

Who is responsible for ensuring your Compliance Monitoring Programme is effective and will provide a due diligence defence in the event of a challenge by the regulator?

WHAT CAN YOU EXPECT FROM A REVIEW BY CCC?

AUTHORISATION DETAILS & ORGANISATIONAL STRUCTURE

We will verify information already given to the regulator, has the firm provided false or inaccurate information previously? Is the information on the FSA register correct?

BUSINESS MODEL – SALES CHANNELS & THIRD PARTIES

How do you generate turnover/profit from your activities? We will explore all types of sales channels. We will want to know the nature of the arrangements and want information on each third party. Are there any activities undertaken that could undermine strategies put in place to improve conduct?

REGULATORY COMPLIANCE: BUSINESS POLICIES, PRACTICES & PROCEDURES

Are your policies, practices and procedures documented and who authored them? How often are they reviewed and updated? Are there details of any changes implemented in response to a lack of effectiveness identified?

SKILLS, KNOWLEDGE & EXPERIENCE

What training and development is in place? Evidence will be required to support all your answers and we will look for staff training schedules, certificates, qualifications, tests and results and personal development files.

PRE-CONTRACTUAL ISSUES

  • Marketing
    Your advertisements and website will be checked, are all changes signed off and checked by a legal firm? How do your marketing and oral/written representations square up?
  • Affordability
    Evidence will be requested of how you concentrate on customer outcomes – we will look at the reasons for arrears – are any adverse outcomes wholly or partly attributable to a deficiency in the assessment procedure?
  • Adequate Explanations & Disclosure
    How do you ensure consumers have listened to/read and/or understood the PCI? Staff will be asked, calls may be listened to, transactions may be observed, and records will be accessed to check for evidence that the correct information has been given.

VULNERABLE CUSTOMERS

We will most certainly be looking for specific provisions for the fair and appropriate treatment of vulnerable customers. Policies and procedures will be checked against what happens in practice.

COMPLAINT HANDLING

Who is responsible for – and who deals with – complaints? Records will be checked to make sure consumers are informed of the process by the time the agreement is made. Complaints will be checked to ensure written acknowledgements and final responses have been sent in the required timescales; and has any appropriate remedial action been taken as a result of complaints being reported as part of MI?

So, there we have it!

Why not ask CCC to conduct an onsite review to make sure your firm is ready for a visit by a regulator!

Here is what some of our customers had to say

  • Consumer Credit Compliance helped us getting through a nerve wrecking period of applying for full FCA authorization in the High Cost Short Term Credit space (a.k.a. payday loans). Our business depends on our FCA license and we could not be able to work without it. Our industry is also very strictly regulated and every aspect of the application had to be thoroughly examined. We had to make sure we are 100% compliant in everything we do including our websites, our marketing standards and practices, our regulatory business plan, business continuity policies, local approved persons and more. Consumer credit compliance were always professional and ready to help and this is what matters most! We also intend to use their ongoing support program for ongoing compliance

    Avner Brodsky
    Money Gap Group Limited

Contact

Windsor House, Cornwall Road, Harrogate, HG1 2PW

01423 522 599

info@consumercreditcompliance.co.uk