Top 10 Tips on being FCA Regulation Ready

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Regulation Ready

HireRight recommends financial service firms take the following steps to mitigate the risk of falling below minimum standards and competitors:

  1. Plan – Have a plan for the next two years to ensure that you are ready not only for March 7 2016 but also 2017 when the rules are applicable more widely.
  1. Review your policies – Map out and allocate responsibilities. Ensure you have policies in place to support your new hire process and particularly your approach for existing staff.
  1. Identify those affected – Take ownership of the new regime, clearly allocating Senior Manager responsibilities and identifying who sits within scope regardless of job titles – it is the roles and responsibilities which are key.
  1. Communicate – These policies need to be clearly and thoroughly communicated internally to all staff affected in the UK and beyond. Ensure your Senior Manager and Certification Regime staff know who they are and what the new regimes and procedures mean for them.
  1. Implement a new hire “fit and proper” assessment – Review how you are assessing it now and agree on any changes needed to meet the new regime. Decide how you will inform candidates so they fully understand the implications.
  1. Introduce an annual “fit and proper” assessment for senior employees – This should focus on the information that could change during employment (e.g. financial standing, criminal records, other business interests, aspects of behaviour). Decide how you want to assess it and what process is needed to support that, both in the UK and internationally.
  1. Define how you will handle negative/changing information – Agree your tolerance levels and your review and appeal processes.
  1. Engage your key stakeholders – Teams responsible for change management, employee communications, compliance, talent acquisition and business functions all need to be engaged in the process and clear on what is happening.
  1. Engage your partners – Make your recruiting firms aware of the changes you are making and ensure you have agreed with your screening partner what is happening and when.
  1. Document everything – Be sure to document everything, and consistently. Be clear how you will store information and how long for. Be ready for when the FCA comes asking questions.

 

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The HireRight Blog is provided for informational purposes only and should not be construed as legal advice. Any statutes or laws cited in this article should be read in their entirety. If you or your customers have questions concerning compliance and obligations under United States or International laws or regulations, we suggest that you address these directly with your legal department or outside counsel.

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