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.
Get Advice Now
FCA to hold webinar to help firms implement new regime
The Financial Conduct Authority recently issued a reminder to firms about the Senior Managers and Certification Regime (SM&CR). In this reminder the regulator has recommended that firms should now be preparing for 9th December 2019, when the new regime comes into effect. In support of firms’ planning for SM&CR the FCA are holding a webinar …
May 24, 2019 at 9:16 am
Retained Provisions of The Consumer Credit Act
Regulation of consumer credit activities has been something of a patchwork. Some elements are still covered by the original Consumer Credit Act 1974. This includes restrictions around broker fees and statutory instruments such as the form and content of credit and hire agreements. In 2014, when FCA took over the regulation of consumer credit, they …
April 8, 2019 at 1:42 pm
FCA Thematic Review of Debt Management Firms
FCA have now published TR 19/1. This is the second thematic review of the debt management sector, including fee charging and free-to-customer organisations. The full report can be found here >> https://www.fca.org.uk/publication/thematic-reviews/tr19-1.pdf Whilst FCA identified that the debt management sector has made improvements there is still a lot of work to do. Listed below are …
March 22, 2019 at 10:17 am
Credit Card Charges
FCA have now publicised a letter sent to all credit card companies. The letter follows their review into credit card fees and charges. The key findings are as follows: Customers who miss a payment are often incurring multiple charges in the same billing cycle – for example a missed payment fee, a bounced direct debt …
March 12, 2019 at 6:04 pm