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What is it?
•Guidance in creating a compliant disclosure document with a compliance review and feedback.
•Template compliance document bundle, including:
–Whistle blowing policy.
–Conflicts of interest policy.
–Complaints procedure, consumer guide for complaints and complaint handling template letters.
–Template Compliance report and plan.
–Templates for gift and entertainment register/breach register/return cheque register and complaints register.
•Updates throughout the year.
Why?
•All firms are required to have Disclosure Documents – the FSA state that “Disclosing is at the heart of giving good advice.” An FSA review of documentation found that surprisingly high proportion still failed to comply in various specific respects.
Principle 8: Conflicts of interest
A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client
•All firms are required to have in place appropriate and effective procedures for dealing with complaints. July 08 - the FSA imposed a public censure on a firm for serious failings in the way it handled mortgage endowment complaints. The fine would have been £400,000 had it not been for it’s financial situation.
•Principle 3: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
When?
•Firms new to authorisation
•Firms who are growing and require a structure developed
•Firms who want to have an improved Management Information (MI) reporting structure
•Firms who have concerns over their complaint handling process
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