Getting priorities in order for FSA authorisation
Q. My firm is planning to apply for Financial Services Authority authorisation before the end of May - what should our priorities be?
This is an almost impossible question to answer without knowing quite how much work the firm has already done and what compliant procedures are in place.
The trade press, insurers and others have all offered advice, briefing papers, and free or low-cost seminars on compliance issues throughout 2003.
While all of these have been useful contributions to the dissemination of information, the reality is that one size does not fit all when it comes to regulatory preparation.
Many firms are in danger of becoming 'compliance information junkies' and moving from seminar to seminar, desperately hoping to find a suggestion that regulation will go away or be found not to apply to them.
It is time to face up to the reality of regulation. If you have appointed a compliance manager or director make sure their action plan is in place, with achievable timescales appropriate to your firm. You should also consider whether you wish to apply before the end of May.
If you have not tackled these issues you must either find the time to do so or, if you feel unable to go through the process unaided, seek external support.
While regulation will be proportionate to the size of the firm and largely risk based, all firms will have to pay attention to the basics. Some of the areas to be tackled include permissions, controlled functions, approved persons, training and competence, compliance, assessment, solvency, complaints procedures, handling of clients' money, and terms of business.
The priority is to assess what you can do yourself and seek appropriate support if necessary. Always remember to seek advice from a compliance and support partner who has an understanding of the general insurance sector and your business requirements.
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