This policy template documents the systems and controls in place to prevent anti-bribery and corruption.
NACFB members firms should be vigilant about bribery and corruption, which are both criminal offences under the Bribery Act 2010, whether committed in the UK or abroad.
Member firms are expected to have considered and taken steps to address the risk of bribery and corruption within their business, including where these risks come from third parties.... Details
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This policy template documents the systems and controls in place to prevent financial crime, which you may otherwise be at risk of committing money-laundering offences.
Although mortgage brokers, general insurers and general insurance brokers are not subject to AML rules and the Money Laundering Regulations, you still need to have systems and controls in place to prevent financial crime. You are subject to the Proceeds of Crime Act 2002.... Details
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This template will support members operating as Principal’s with one or more AR/IAR relationships. It sets out key responsibilities placed on Principal's in terms of relationship management and oversight and will support member firms to evidence compliance with their responsibilities. The next tab hosts the AR/IAR Oversight Activities Template. This includes areas the FCA are likely to query and examples of how your business may satisfy these. The NACFB would encourage members to... Details
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This is an Appointed Representative/ Introducer Appointed Representative Agreement.
This is a contract documenting the arrangement between the Principal and the AR/IAR. The principal takes full responsibility for ensuring that the AR/IAR complies with the FCA rules and operates within the permissions held by the principal firm.
The document takes into account Consumer Duty and includes a clause for agreeing to comply with the cross-cutting rules and four consumer ... Details
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In the event of unforeseen interruption, this plan details appropriate arrangements to ensure your company can continue to function and meet the regulatory requirements.
SYSC 3.2.19 states companies should have such appropriate arrangements in place and these should be regularly updated and tested to ensure their effectiveness. It is aimed at ensuring, in the case of interruption of your systems or premises, any losses are limited and functions and data are preserved... Details
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Template certificate, for issue to individuals who have been assessed to perform a Certified function.
This certificate should be re-issued annually, following each annual assessment.
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This document outlines the different certification functions and gives an explanation to help in confirming which certification functions are applicable.
Note:
Not all of the functions in this table will apply to all firms and firms are only required to apply those that are relevant.
If these roles don’t apply to your firm, then you won’t have any Certified Staff. You don’t need to apply the Certification Regime.
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This document effectively outlines to employees that they must clear their desks at the end of each workday to reduce the risk of information theft, fraud, or a security breach caused by sensitive information being left unattended and visible in plain view.
By always keeping sensitive papers and computer files securely stored with a clean desk policy, you’re able to reduce the chances of employee negligence or theft. Not looking after your information properly could have ... Details
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CMC template correspondence following FCA review into Motor Finance Sector.
This document provides members with a template for download, which can be edited and amended as necessary, to assist you responding to claims that Brokers owed a fiduciary duty to Customers and failed to disclose appropriately information relating to commissions brokers would earn.
This document will require you to make some amendments, to suit the particular claim you have... Details
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This document, sent to the client, summarises the outcome of your investigation into the complaint of a complaint received.
If a consumer remains dis-satisfied and takes their complaint to the FOS, they usually use your final response as the starting point when they look at the case. Please ensure this is a sensitive reply that shows you are concerned for your client.
This document has been updated to incorporate Consumer Duty regulatory... Details
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This document acknowledges to the complainant the complaint has been received, you consider the complaint to be resolved and if the complainant decides that they are still dissatisfied, they may refer the complaint to the FOS.
When you consider a complaint to be resolved within the timescale, you must send this document to the complainant, which can be tailored and used for different complaint types.
DISP 1.5... Details
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This policy effectively outlines the clear and fair process your business has adopted to ensure the effective handling of a client complaint.
You must have your own internal complaints handling procedures and comply with rules (set out in the DISP chapter of the FCA Handbook which sets out timescales for which responses to complaints must be given to customers.
https://www.handbook.fca.org.uk/handbook/DISP/1/3.html)
This document has been updated to... Details
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This document demonstrates and evidences how your businesses handles and resolves complaints in respect of your activities with your clients.
You must be able to outline how your business adheres to the rules and guidance set by the FCA under their DISP Sourcebook in respect of complaints, to evidence understanding of the rules and guidance set out and ensure clients are treated with fairness and courtesy.
This document has been updated to incorporate... Details
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This register evidences all complaints received and timescales in which they were resolved, in adherence with DISP.
Record Keeping for complaints is a requirement under the DISP Sourcebook and is reported in your RegData return. Businesses must retain all complaints received for a minimum of 5 years (DISP 1.2).
Document updated March 22 with minor changes to formatting.
This document has been updated to incorporate Consumer Duty regulatory... Details
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A business must notify the FCA immediately it becomes aware, or has information which reasonably suggests, that any of the following has occurred, may have occurred or may occur in the foreseeable future:
(1) the firm failing to satisfy one or more of the threshold conditions; or
(2) any matter which could have a significant adverse impact on the firm’s reputation; or
(3) any matter which could affect the firm’s ability to continue to provide... Details
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You should record and notify the FCA if a breach has occurred or if you have information that reasonably suggests a breach may occur and have a significant adverse effect on your company’s reputation or be of serious detriment to a client.
You must notify the FCA immediately of any such potential or actual breach, and regularly review the reporting document to aid you to meet the FCA’s requirements.
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This document includes high-level objectives and the procedural steps to complete quality assurance testing over the day-to-day activities of your company.
Compliance monitoring can determine where your processes can be simplified and made more efficient, saving cost, time and increasing your competitiveness.
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This document provides an independent review of the operational work performed by your firm, with a focus to confirm whether operational tasks are being performed in line with operational procedures, and to confirm whether those operational procedures continue to reflect current regulatory requirements.
The FCA requires all companies to report on the overall standard of compliance and recommend improvements to procedures. This will enable you to report to the FCA that... Details
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This document evidences the review conducted based on the compliance monitoring programme.
This document has been updated to incorporate Consumer Duty regulatory guidelines. 09/23
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This plan documents the systems and controls your business has in place to detect and prevent breaches of rules.
This ensures effective adherence of your own policies and of UK and EU legislation as well help operations to run smoothly, to focus your workforce on the broader business goals and prevent potential enforcement action.
This document has been updated to incorporate Consumer Duty regulatory guidelines. 09/23
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Conduct Rule Breach Reporting
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The Conduct Rules apply to all firms, including branches. These Conduct Rules to all employees within a firm – not just approved individuals. These set of enforceable rules set basic standards of good personal conduct, against which the Financial Conduct Authority (FCA) can hold people to account. They can be found in the COCON chapter of their Handbook.
This document has been updated to incorporate Consumer Duty regulatory guidelines. 09/23
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This document evidences your company’s understanding of the procedures in place to manage all potential and actual conflict and outline the rules regarding such issues.
SYSC 10.1.1 states businesses must take reasonable steps to identify these conflicts and the responsibilities of your workforce and your company in resolving these.
Updated Feb 22 with addition of relevant training modules available to help with the implementation of this... Details
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This document encourages the disclosure if actual, potential or perceived conflicts of interest, in order to protect the integrity and reputation of you and your company. This provides evidence of conflicts identified and mitigated.
This template was updated with minor formatting changes May 22.
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Consumer Duty Gap Analysis Template
Firms must have a robust implementation plan to meet the new standards set by the FCAs Consumer Duty. This comprehensive suite of worksheets created by the NACFB will assist Members to conduct a Gap Analysis process and evidence the steps taken to assess, record, analyse, remedy and report against this key requirement.
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