What is missing?

Q. We are a 25-strong, mainly commercial brokerage. We have received our minded-to-authorise letter, but I feel that, after all the preparatory work earlier in the year, there must be more to do. What am I missing?

A: This is impossible to answer without spending some time with your firm. However, from our experience in working with many firms of a broadly similar profile to yours, most have done an excellent job on the 'mechanical elements' of compliance.

You will have identified permissions required, who the approved persons are and who is responsible for which control function. This will have formed part of the submission of your HSF forms.

I suspect that you will have identified any introducers or appointed representativess, and established with the various insurers the position over risk transfer.

One of the principal areas in which we find there is work to be done is in training and competence, which is a high priority of the Financial Services Authority. A robust and dynamic T&C plan will ensure that the public is protected, and that individuals in the firm only handle work within their competences.

Where many firms fall down is in the proper training of, and understanding the role of, supervisors in a regulated environment. Supervision and monitoring are cornerstones of any quality T&C scheme.

Hand in hand with that is the difficulty some firms perceive in assessment of competence of individual staff members.

The Chartered Insurance Institute has done an excellent job here in tandem with the British Insurance Brokers' Association in offering the BrokerASSESS suite of multiple-choice questions and case studies, available to any broker firm. If you are a BIBA member firm, you should talk to Paul Garland and their regulatory advisory executive, Steve White, about the range of support available to members through BIBA.

I would recommend that you revisit your T&C plan and see how the elements that I have highlighted stand up to scrutiny.

If you need guidance, talk to whichever firm has been helping you with your compliance preparation.

It is important to remember that assessment of staff needs to be ongoing, and your T&C plan should be revisited regularly to ensure that it is still relevant to your business and its needs.