It seems like ages since our last Newsletter – in fact it’s only been four weeks. Time flies when you’re in Lockdown!
As previously, this Newsletter highlights some of the key Covid news releases from FCA since then, along with some other news.
Read all about it!
Rather than wait for Fulcrum Compliance to tell you, hear the news direct from the horse’s mouth. FCA are offering an email update service for firms on a weekly or daily basis. Subscribe to this via their web site here.
Crime is all around
We wrote in our last Newsletter (“Let’s be careful out there…“) about some of the crime risks posed by home working. Since then FCA have advised on their own expectations of firms. Some key points:
- Don’t adjust the risk parameters for your automated screening just to reduce the number of alerts you receive;
- Do prioritise what you’re going to look at, including those transaction monitoring alerts and customer reviews;
- Do do this on a risk basis and have a plan to return to business as usual.
And no prospective customer is going to come into your office to allow you to copy their passport and gas bill – use electronic verification or ask the client to send you scanned copies.
Don’t be wet…
Nor are you going to get a wet ink signature on anything. FCA has said that wet ink signatures are not actually required by FCA rules and that you are allowed, having considered the risks, to get electronic signatures.
And you’ll need to look at your customer facing paper processes. Is there a pile of post building up at the office? Can someone go and collect it? Have you told clients what you’re doing? FCA have said that “while we understand that obligations for paper documents may be difficult to meet on usual timescales and will show flexibility in how we approach such issues, we expect firms to send communications in a timely manner.” See their full statement here.
Back to the office?
At the time of writing, the Government is just starting to twitch the edge of the curtain that may usher in a return to your office premises.
Whilst not an FCA issue per se, FCA firms will, along with all others, need to consider their responsibilities as employers to ensure that any return to work is safe. This will include staggered working times, variable attendance and enabling social distancing once in the office. Given the layout of some offices, this will be easier for some than others. Now is an ideal time to be considering these steps.
Alternatively, given the success that most firms have had in home working and remote meetings, firms might reasonably choose to sit out any early return to work until the residual restrictions in place are sufficiently minimal as to pose no impediment to a full return to “normal” working.
Such a decision will clearly mean a longer period at home and will need to be taken after a proper consideration of clients’ requirements and employees’ needs.
Start planning now!
Do you remember..?
We wrote in our last Newsletter (“What did you do…”) that with so much going on, you should consider maintaining a “running commentary document” recording the steps you took and when you took them.
When this all ends it’s possible that FCA will want to know how you continued to meet – or more likely did not meet – your obligations. Such a document will make it much easier to answer FCA’s questions than trying to think back to what actually happened all those months ago.
A Question of Culture
Moving away from Covid, just before the Lockdown took effect, FCA released in March a further Discussion Paper (DP 20/1) on the subject of firm culture, “Transforming culture in financial services – driving purposeful cultures”. This paper takes a closer look at what the purpose of a financial services firm is – or should be.
Although not a policy document, this Discussion Paper gives clear views on what FCA think the purpose of a firm should be – and in spite of the cautionary contributions in the DP from industry leaders, it’s clear that FCA’s own view is that a firm’s purpose is about far more than the grubby business of making money.
The impact of Covid has been to knock this and many other FCA initiatives off track, but make no mistake – FCA will return to this subject. In the meantime, see our own view on this subject in the May issue of Compliance Monitor.
FCA herald the end of Gabriel
One initiative the FCA has chosen to press ahead with in spite of Covid is the gradual wind-down and replacement of its principal data collection tool, Gabriel.
If you’ve logged in to Gabriel since 2 April, you’ll have noticed that you’re taken through a series of mandatory steps to register for the new platform. You’re then asked to confirm your existing Connect login details. After that, it’s business as usual with Gabriel until it finally loses its wings.
FCA has published some details about how to register for the new system, but if you’re an existing user and have completed the above steps, you should be done.