The biggest challenge for any firm, and particularly for small firms, is what a compliance system sufficient to meet FCA requirements should look like. This applies equally to a firm’s own business but also where it has responsibility for Appointed Representatives or agents, or where it is auditing firms to whom it outsources any part of its business.
What are the main considerations?
Firms first and foremost should consider their obligations under the FCA’s High Level Principles for Business (PRIN), and in particular, PRIN 2, the requirement to conduct business with due skill and diligence, PRIN 3, which relates to the proper organisation of its business affairs, PRIN 5, the requirement to maintain proper standards of market conduct, and PRIN 6, the overriding obligation to treat customers fairly (TCF).
For any organisation, compliance with proper business standards and regulatory requirements should be at the heart of its corporate governance agenda.