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?
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?
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.
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.
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!
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