Reviews
We regularly undertake compliance and regulatory reviews for FSA authorised firms. These can either form part of our ongoing compliance support service or be arranged as a free-standing exercise. The scope can be as broad or narrow as the client wishes. We can undertake a wide-ranging review of a firm's overall state of compliance, or focus in more narrowly on, for example:
- specific products or service areas;
- specific branches or locations;
- systems and controls (in general, or in a specific area);
- the structure and effectiveness of compliance departments;
- documentation.
Whilst most reviews are undertaken at the initiative of the firm concerned, we are happy to carry out reviews for third parties such as the FSA, insurers, owners or others.
Examples of recent review work include:
- a review of the discretionary trading activity of a private client stockbroker as part of an investigation into suspected account churning;
- a comprehensive compliance review against the FSA's requirements for general insurance firms, for an intermediary which had internally identified some potential problem areas;
- a review of the acquisition finance activities of an international bank in order to assist the group compliance function develop appropriate monitoring procedures and regulatory training programmes;
- a review of systems and controls and ICOB compliance of the insurance activities within a group whose principal business is not insurance. Our report ranged widely, addressing wider issues of corporate culture, organisation and controls as well as the detail of the ICOB requirements for individual sales;
- a review of a sample of a firm's PPI telephone sales for compliance with FSA requirements.