Putting into action the most important rules since M-Day in 2004 will no doubt be taking so much priority that other policies can get somewhat neglected.
The Clear Desk Policy is a case in point. It’s always gone a little under the radar anyway – though it has been part of the regulator’s guidelines for many years (including in its previous incarnation as the FSA).
This policy, states the FCA, aims to prevent inappropriate access to sensitive client information. It’s a simple rule that implores brokers to put sensitive documents such as copies of the mortgage application, copies of bank statements and photocopies of ID from their clients in a safe place. Unfortunately many brokers still use paper files and also leave these files on their desks for any burglar or other untrustworthy sort to come across. These files tend to stay there gathering dust until the mortgage has completed.
Through complacency, lack of time or a genuine belief that the regulator will never check up on this rule, 90% of brokers who don’t use a CRM system continue to keep all of these highly sensitive documents on their desks for all to see.
It is only a matter of time before the FCA takes action. So what should firms be doing?
One thing is clear, technology is key. A good CRM system will help to reduce the need for paper copies of any documents, allowing you to scan and upload them securely as well as filing them electronically and sending necessary documents to the client.
The second choice is to still continue with existing paper files but invest in lockable and also fireproof filing cabinets. Then at the end of each day ensure all paper files are packed away. This part of the FCA rules also extends to files being locked away if you leave your desk for any period of time such as a lunch break.
The regulator may seem pre-occupied at present but the fact is the Clear Desk Policy exists – ignore it at your peril.
Phil Whitehouse, managing director, MCI Mortgage Club