Getting ready for the people phase of the European Mortgage Credit Directive TC News Jan 17
Published: January 2017
Getting ready for the people phase of the European Mortgage Credit Directive TC News Jan 17
Published: January 2017
For those interested a quick reminder – responses are due by the 26th January on the future mission, remit and role of the FCA.
Published: January 2017
This Occasional Paper from the FCA takes a look at behavioural biases, morality and culture in the context of professional decision making within organisations. A recommended read for those involved in “People Risk”.
Published: January 2017
The clock is ticking and the 7th March 2017 will soon be with us. This will see a number of conduct requirements introduced to banks and insurers namely:
In the majority of firms policies have been designed, and where already existing, reviewed and updated. Processes are in place to produce the certificates and “dry-runs” have been performed ahead of time. Therefore I would urge firms to review the detail of the processes in place. Develop a number of scenarios to assess against the important considerations of whether the individual in your opinion has the honesty, integrity and reputation; competence and capability; and financial soundness to perform their role.
The Regulator has now ensured that responsibility lies with firms to ensure that individuals with a poor track record are identified. This brings with it a number of challenges in demonstrating compliance with the rules, as well as consideration to common law, a desire to avoid discrimination and maintain harmonious employer / employee relationships.
Therefore run through some practical examples; how will you handle an individual challenging a regulatory reference, update the reference records and, if disparate systems or paper records exist, provide references for staff 6 years previous.
Firms with experience of the implementation of the Conduct Rules for SM&CR staff will have evaluated the training, demonstrating that staff understand the rules and their own responsibilities. This learning can be applied to the wider population. Furthermore, ask how do you measure compliance with the rules and demonstrate that your culture is working in practice?