Skilled Person Reviews
As from 1 April 2013, Bovill was appointed to the Skilled Person Panel in the following areas: Client Assets, Conduct of Business, Financial Crime and Prudential (Investment Firms, Intermediaries and Recognised Investment Exchanges). Please click the FCA and PRA websites to see the Panel in full. Please contact Rebecca Thorpe (rthorpe@bovill.com) for more details.
Under section 166 of FSMA ("s166") the regulator has the power to require a firm to appoint a Skilled Person to produce a report on specified matters. For example, this might involve a review of past business for a specific business area or product; a review of a firm's compliance with the client money and asset rules; or a review of a firm's systems and controls. Firms issued with a s166 Requirement Notice need to select one of the available providers from the published panel to carry out the Skilled Persons review.
Bovill have extensive s166 experience and have been appointed as Skilled Person on numerous occasions to carry out a detailed review and produce a report to the target firm's and regulator's satisfaction. Examples include:
- an extensive review of CASS compliance at an asset management services firm;
- a review of the suitability of the private client wealth management offering of a blue chip firm;
- post remedial review of CASS compliance for a firm holding client money and safeguarding assets;
- review of complaints handling and past business review of a national IFA network;
- post remedial review of the suitability of a wealth management service offering;
- review of past business of the sales of certain "high risk" products made by an IFA firm;
- "shadow s166" review of suitability for a major wealth management group; and
- past business review of the sales of small cap stocks made by a private client stockbroker.
We pride ourselves in carrying out a thorough and considered review of the subject matter in question, and providing a report that is accurate, balanced and fair. Any issues identified in our reports are always accompanied by practical and proportionate recommendations to address any gaps in the compliance framework. We aim to provide complete transparency to the target firm and the regulator as we progress the investigation to ensure findings are fully discussed prior to issuance of the Skilled Persons report.
If the FCA, PRA or Bank of England have requested you appoint a Skilled Person, or indicated that they might be considering doing so, please contact us to discuss how we could help.