Ten questions you should ask yourself.

Governance – Senior Management Arrangement, Systems and Controls asks:

Have FSA responsibilities been included in the job descriptions of approved persons and senior managers?

The FSA see this as key to establishing a culture where all those responsible for the business can see a direct link between the role they have and how regulation impacts on that role.

Can you demonstrate there are contingency plans in place for dealing with a crisis, e.g. a business continuity plan.

For example – how will you communicate to members of staff and customers?

Have you alternative office premises?

How do you store your financial accounts, cheque books etc?

Can you demonstrate you have a programme in place, approved by senior management, to monitor compliance and conduct compliance audits?

Ensuring this is actually documented and has been communicated to those affected is key to ensuring that everyone understands what is expected, how often and by whom.

This may be a familiar question by now but it’s still worth asking:
Have you undertaken a review of all business areas to ensure that you are treating customers fairly?

We have two deadlines looming on TCF, 31st March and 31st December 2008. Are you absolutely certain you will be ready. Time flies so take action now.

Do you have a process in place for dealing with peaks of work?

Some peaks occur seasonally but other may occur without notice. Do you have contingency to cope or would client service suffer and consequently your commitment to TCF.

Can each approved person articulate the firm’s stance on risk assessment, measurement and control framework?

In order to manage the business each approved person must understand the high level controls the business has in place and how these help to mitigate risk for the firm. If they can’t articulate what this looks like then they probably aren’t adhering to the controls either.

Do you have in place professional indemnity (PI) insurance covering claims arising from work carried out from the date on which the firm became FSA authorised?

An obvious one I know, but is it up to date, still adequate and was it in force at the right time.

Do you have written procedures in place covering the sales process?

The Sales Process means, but not exclusively, the following:

Categorisation of clients, retail/commercial
When documentation needs to be used
Status disclosure
Product disclosure
Scripts for telephone sales

If you issue financial promotions, do you review these to ensure any limitations on savings have the same prominence as savings, e.g. font size etc?

Who reviews your financial promotions to make sure that your perceived benefits of the product do not dominate the literature whilst at the same time the limitation and exclusions are buried.