Bespoke Compliance Procedures
The foundation of a compliant business is having relevant and proportionate procedures in place. These should be well documented, evident in every-day practices and kept up-to-date. The FCA will expect consumer credit firms to have full compliance procedure manuals and be able to evidence that they operate in accordance with these manuals.
Establishing written compliance procedures was the main requirement of firms achieving authorisation in 2014; this was the basis on which the FCA licensed firms. Now the FCA has moved its attention to supervision and will reasonably expect firms to have these procedures documented and embedded in their business. Firms who do not may find their consumer credit licence revoked, meaning that they cannot continue to legally trade. In serious cases this may be permanent or at least until the firm has demonstrated that its written procedures are adequate.
Compliance procedure manuals act as a comprehensive guide that sets out exactly how a firm manages its business. For most firms this will include sales processes, complaint handling, financial promotions, incentives, staff training, quality assurance and governance.
Many firms fail to document compliance procedures that accurately reflect day-to-day practices nor to asses if their compliance procedures deliver good customer outcomes.
Once compliance procedures have been implemented they have to be monitored to ensure they are being followed and effective. They must also be reviewed regularly to ensure they stay up-to-date with business and regulatory changes.
Helping firms to develop compliance procedures is a core speciality for CCAS. We can ensure that your manuals are bespoke to your business and help you to implement them. We can also help you to review your current documentation to ensure that it is appropriate and will stand up to scrutiny from the regulator.
To find out how we can help you with compliance procedures, get in touch with us today by clicking the button below.
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Retained Provisions of The Consumer Credit Act
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April 8, 2019 at 1:42 pm
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Credit Card Charges
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