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Training
and competence has been in place for a number of
years now and contributes to the FSA’s objective
to ensure that there is confidence of
investors in the UK financial system. Previous rules
on Training and Competence had been prescriptive
in what a scheme should cover. However as part of
the FSA’s own move to be a risk based regulator,
firms can design what is an appropriate scheme for
their own regulated environment.
However without that prescriptive element, it is
very difficult for firms to benchmark their own
T&C scheme against other firms’ schemes
and the regulators requirements. Often the only
test of whether the scheme is satisfactory or not
is when the regulator tells you that it isn’t!
By that time, remedial action can require advisers
to be retrained, and so often they are
unable to perform their normal commercial roles
until remedial action has been satisfied.
Gem Compliance can
review your existing T&C scheme to ensure that
it covers the principles of the FSA rules, but also
where there is flexibility under the rules, that
we ensure there is sufficient evidence on file,
either in the scheme – or in individual records
– that the scheme is appropriate and effective.
T&C should be seen as a development tool rather
than an audit. We can work with Human Resources
and/or Training departments to ensure that the T&C
scheme is seen not just as a compliance tool but
as an employee development tool which also satisfies
regulatory requirements. |
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