Assessing Suitability
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FSA view
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"As we apply our intrusive and intensive supervisory approach, we will be looking to see how firms have acted on our report." Nausicaa Delfas, Head of Conduct Risk, FSA 19/5/11
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All about Suitability
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A new perspective on the Suitability rules in COB was provided in Finalised Guidance in March 2011 is prompting many firms to re-consider their T&C Schemes.
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Contact to discuss
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Email enquiries@ctp.uk.com or call 0203 170 5579 to discuss your requirements.
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Assessing Suitability Final Guidance was released in March this year, we can now expect intensive and intrusive supervision on this topic.
Firms will need to demonstrate how they are responding to the guidance and
the suitability of products and discretionary investment portfolios is a key to delivering better outcomes for customers and clients.
The FSA will be reviewing files to establish that they demonstrate the competence of Advisers and Investment Managers to deliver the new standards and taking tough action where they find that suitability cannot be demonstrated.
We have a tried and tested solution that assists clients to re-engineer the way in which their people deal with this issue and improve the service they provide while satisfying regulatory standards.
Stage 1 : Embedding the Principles of Suitability.
Option 1: Face to face training which would incorporate;
- The background behind the T&C assessment process
- The investment advice process
- The requirements of KYC
- The importance of hard and soft facts
- Explaining Risk
- Compiling a robust suitability letter
- The Company standards that will be used to Assess Competence
- The positioning of the Assessment Centre
- A DVD of what competent looks like
Option 2 : E learning suitability course
This is a bespoke Self Study computer based learning event which would incorporate case studies and questions to validate the learning. Using Assessors who have extensive financial service experience and have been assessed as being competent in the areas of Observation and File checking and financial service experienced role players to ensure consistency and impartiality, the assessment centre would encompass the following;
Stage 2: The Assessment Centre
- Case studies that are relevant to your business/ clients
- Assessment of Client Fact Finding through observation
- Assessment of Client Presentation Meeting (present recommendation) incorporating the positioning of reviews) through observation
- Assessment of a Suitability Letter against defined criteria.
Stage 3: Development Programmes
These would be based on the outcomes of the assessment centres and through our experience usually cover;
- Risk categorisation
- Questioning techniques and the ability to elicit soft facts.