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Where FCA Regulation is today. Are you there too?

Where FCA Regulation is today. Are you there too?. Stephen Atkins SA Compliance Management Ltd. Skilled Persons Panel. Governance, Systems & Controls and Risk Bank of England Prudential Regulatory Authority Financial Conduct Authority. FCA Permission and Landing Slots for Pawnbroking.

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Where FCA Regulation is today. Are you there too?

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  1. Where FCA Regulation is today. Are you there too? Stephen Atkins SA Compliance Management Ltd

  2. Skilled Persons Panel Governance, Systems & Controls and Risk • Bank of England • Prudential Regulatory Authority • Financial Conduct Authority.

  3. FCA Permission and Landing Slots for Pawnbroking Sector = Higher Risk Firms April 1, 2014 = Interim Permission January 1, 2016 – April 1, 2016 = Application period - FULL permission only.

  4. Other FCA Activities carried out by Pawnbrokers • All permissions have to be requested from the FCA, simultaneously, and at the first applicable Landing Slot • Pawnbroking permission applications will move to an earlier date if the firm carries out other activities

  5. But…….. If a firm had not amended its CCL to remove any unwanted permissions the FCA will = • Apply the Landing Slot period of the unwanted permission if it precedes 01.01.2016 • Require the firm to vary its permission • Not allow the the firm to revise its Landing Slot to 01.01.2016

  6. Unauthorised Pawnbroking • Any firms who are not listed on the FCA Interim Register • Contact the FCA if this is you, or you know of a firm without permission • ‘Buy Back’ is not regulated, but the FCA will check it is not used as a resort for vulnerable customers

  7. FCA versus OFT • “The FCA will adopt a higher starting point for conduct standards than many firms may realise.” • FCA Risk Outlook • “There is a view that people are not frightened of the FSA. I can assure you that this is a view I am determined to correct. People should be very frightened of the FSA.” • Hector Sants, FSA CEO, March 2009

  8. FCA Interim Permission 1 Does not allow a firm to delay its compliance arrangements and preparation until its landing slot. 2 The 6 month period has ended which allowed reliance on previous CCA process.

  9. Where are you now?Can you evidence FCA compliance? From April 1 2014 all consumer credit firms had to comply with the FCA’s high level standards: • The Principles - PRIN • The Systems & Controls Rules - SYSC • Status Disclosure - GEN • Financial Promotions – COBS/CONC

  10. What should be in place today • Compliance Plan ( written policy for ownership, valuations, early redemptions, TCF…) • Compliance Monitoring Plan • SYSC Plan See FCA website for the content of these plans

  11. And, if not started, build today • Regulatory Business Plan

  12. Action: SYSC wef 01.04.14 Principle 3states = ‘a firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk-management systems’

  13. Your responsibilities under SYSC To produce and maintain written processes for = • Organogram • Controlled Functions & Job Descriptions • Senior Management arrangements • Regulatory Business Plan • Compliance Plan • System and Controls • Internal Audit • Financial Crime

  14. Action TCF & Conduct Risk Produce a written policy that evidences – • Customers are central to your business • Customers achieve their expected outcome and understand what is involved • How the firm knows what customers are thinking • The firm’s conduct risk appetite • The firm use of internal audit and MI • How this information is used to control conduct risk and what does the firm do when things go wrong

  15. What’s next? • FCA Electronic Reporting • Compliance Support Programmes • Networks • Complaints Management Firms • FCA pre-full authorisation visits to some large firms and random small firms

  16. Checklist • Compliance Arrangements in place. • Regulatory Business Plan progress. • TCF is active. • FCA website regularly reviewed. • Company accounts are up to date. • Technology capability reviewed. • You have read the FCA Authorisation and Guidance Forms.

  17. NPA THANK YOU stephena@sacm.co.uk

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