As 2019 draws to a close, it's traditional to turn our attention towards planning for the future.
I am not one for New Year's resolutions myself, as I never keep them, but I do think about what’s in store for the year ahead and how to prepare for it.
2020 will be the first year under the senior managers and certification regime (SM&CR), and that means there’s at least two brand new tasks that will have to be planned for and completed.
With that in mind, let's make a list
for Santa of the compliance tasks ahead...
New task 1: Code of conduct training
On SM&CR, all senior managers and certified staff need to have completed their code of conduct training by 9 December 2019.
Firms need to think about training any remaining staff not already trained to abide by the code of conduct rules before 8 December 2020.
So the questions you will need to consider are around what that training is going to look like, who is going to complete this training, and when and where this is going to take place.
New task 2: Certification
All staff falling under the certification regime will need to receive their certificates no later than 8 December 2020.
As such, similar questions to those above need to be answered.
Before rushing into this though, it's worth putting some thought and preparation into your approach.
For example, how does your firm plan to evidence that a robust approach has been taken to check an individual’s 'fitness and propriety' and 'competence and capability' as required under the new regime?
Do you need to set aside some time to adapt your training and competence plan, as well as train staff on what’s happening?
And the rest
Of course, in the year ahead there will also be the usual myriad of compliance tasks to complete, for example:
- Renewal of professional indemnity (PI) insurance - remember to plan well in advance for this
- Renewal of statement of professional standing
- Statement of responsibility review and update
- Senior manager meetings
- Money laundering report and staff training
- Staff training
- One-to-one and performance review meetings
The list goes on.
'Tis also the season where many people exchange gifts (and I don’t mean my wife taking back the presents I so carefully selected for her).
To help with planning for the year ahead, we've produced a compliance year planner that firms can download and personalise.
It’s a simple format which also allows you to colour code each task according to the senior manager responsible.
By taking the time to populate and personalise the planner, you can create an at a glance view of the compliance tasks ahead in 2020.
We recommend you start with the immovable tasks such as Gabriel reporting and PI renewal, then build in planned holidays, or times where there is a peak in clients being seen.
After that you can schedule in other compliance tasks.
Once completed, copies can be distributed around the office, so everyone knows what everyone is doing (and when).
Now, it's worth bearing in mind what I said at the top of this article about New Year's resolutions.
Don’t publicise this planner if you are not going to use it.
If the FCA ever do come to visit you, the last thing you want to do is have a compliance plan on the wall that you can't evidence that you're using.
We hope you'll find the planner useful.
All that's left for me to say is to wish you a very merry Christmas, and a prosperous (and compliant!) 2020.