Compliant status

More and more we are seeing firms that, having successfully become authorised, have done little to maintain or embed their compliant status. So you are not alone!

You will be aware of the main headings of ICOB, money rules, TCF, T&C, complaints and the like. You could start by drawing up a list of headings and see what material you have and what progress has been made.

You should also familiarise yourself with the information required every six months for RMAR and ensure that is done accurately and in time.

You may wish to engage some outside help in order to do this. the Association of Professional Compliance Consultants website www.apcc.org.uk may be of help.

Also check with the CII and BIBA to see what courses are running that would improve your knowledge. One advantage is you will meet others in similar circumstances, and exchanging contact details with delegates will start to build a reference network.

You also need to establish a budget if you are to do the job properly. A tactful reminder of the consequences of not doing it properly and, despite your appointment, that responsibility for compliance rests with the approved persons who have taken on the controlled functions may be appropriate.

While the FSA is beginning to flex its muscles in general insurance, there are many smaller firms that have not yet had any real contact with the regulator and complacency has set in.

- Ian Ritchie is Managing director, RW Associates.