A prominent retail broking firm in the South-East were required by FSA as part of their Risk Mitigation Programme to review the arrangements in place for ensuring KYC,suitability and best execution.

Following correspondence that had been naively responded to by the client, the FSA were threatening enforcement action on a number of points raised by their visiting team, which they were not happy had been sufficiently evidenced as being addressed.

In order to forestall the potentially financially devastating and expensive and S.166 Review by a “Skilled Person” (SPR) and before any S166 Requirement notice was issued, we were engaged. to immediately review all procedures and report.

We were appointed (with FSA’s consent) to review and assess all aspects of the suitability process and a highly representative number of case files and all complaint files (a small number in total) to ensure there was no customer detriment. We reported to management, who appraised the FSA regularly of how the findings were implemented.

• After a brief period of less than three weeks we had;
  Achieved the FSA’s outcome of clearing all Risk Mitigation Program points
  Reviewed and assessed all complaints and ensured independent assurance that they were not justified
  Reviewed and assessed the clients governance, procedure manuals and sales process, ensuring any gaps were filled
  Reviewed and assessed a number of files and embedded processes where existing arrangements were weak.
  Saved the client approximately £35,000 in S166 Costs and another £15,000 in RMP costs as well as reputational damage.

A City-based specialist brokerage house was visited by FCA as part of a themed review of asset management. Although the visit appeared to go well, on more experienced analysis, the comments made post visit by the FCA could be seen as a warning. The firm thought it sensible to review its governance, corporate and management structures and procedures.

Compliance Consultant were engaged shortly afterwards, to review and update compliance documentation and procedures. After initial discussions, and some assessment by us, this intervention grew with several streams. Apart from providing some gapped policies, a Compliance and updated Anti-Money Laundering policy (the same that we sell on our website, we also conducted a refreshing and delivery of the training programs including conflicts of interest, personal account dealing, fraud, Anti-Money Laundering and other compliance training of broking staff.

We were able to act swiftly and we provided professional, qualified assistance

• Accurate and updated documentation and references
• Required governance for a firm of the size it was, with transmission and embedding of the new material
• Complete and updated training package for all staff
• Full audit trail of all work done, providing satisfaction to senior management that they were on an even keel.
• Saved them potentially around £70,000 in costs of getting in a major consultancy

Whilst involved in a major Risk Mitigation Program (RMP) for a FTSE 100 company, the firm conducting the program management and RMP deliverables were asked to leave the site. Seeing a gap and by having the right skills, we stepped in and stepped up to the job, providing a fully managed service, program and project managing the deliverables through the various governance process, ensuring the senior management approval of the items, then proceeded to package and deliver the requirements to the FCA in the approved format, in addition to our initial workload. This initial 3 month intervention then lasted 10 months until completion and handover to the company staff.

By involving ourselves we provided

• A clear and coordinated track to completion,
• A consistent path of “go to” specialists in this type of work,
• Daily/Weekly (as required) updates to the Heads of Department
• Understanding of the full interpretation of the requirements and prioritisation of the deliverables,
• Qualified people working ‘as required’ not filling seats to perform unecessary activities
• Saving the company an approximate figure of over £175,000 in ‘large’ Consultancy costs