Last week, the FCA fined Standard Life more than £30 million. If the forecasted financial redress to clients impacted by this reg breach is also included, this financial hit is more likely to total close to £100 million! These are staggering amounts, regardless of the size of your balance sheet.
The FCA is serious and “lip service, tick-box compliance” is completely unacceptable and firms who do not embrace a culture of competence and fairness will be held to account and, perhaps of greater concern for many executives in these firms, they will be personally liable.
With Senior Management & Compliance Regime impacting thousands of firms in December this year, the learnings from Standard Life and other recent announcements from FCA are clear.
- Treat customers fairly or we (FCA) will hold you to account
- Make sure employee training and development genuinely delivers retained learning and not just ticks a box!
- Make sure management information is of sufficient depth and quality to substantiate the fit and proper nature of the employees delegated work
If I were a Senior Manager in a regulated firm, I certainly would not be satisfied relying on the traditional annual e-learning, training records to evidence that I have discharged my duties and that the employees reporting to me were competent and capable.
The fact of the matter is, right now, in the vast majority of instances this scant and largely irrelevant evidence is all a Senior Manager will have to rely on to defend themselves.
If your business hasn’t materially changed, the way employee training and competence is achieved and your management information and control frameworks are as they always have been, you could be personally seriously exposed.
A new FinServ firm joins our client herd every week and their Senior Management sleep easy knowing Clever Nelly, our Artificial Intelligence, guarantees employee competence and provides the very highest standard of management information. www.elephantsdontforget.com is the future and its available now, easily deployed, low costs and low admin.