With so little regulatory certainty, advisers must work on their own businesses because a “lack of systems and controls will be indefensible,” he said from the Ricoh Arena in Coventry.
“Hilary Clinton said ‘never waste a good crisis’ so the need to be on the front foot is more important than ever,” he said.
Brokers must better understand complexity, investigate proactivity and get bullet proof external systems and controls, starting with monthly minuted internal review meetings diarised 6 or 12 months in advance with key personnel.
“Expect to achieve little for the first three months, but stick at it and never let any personnel miss the meeting or get them to send a deputy,” he said.
List each activity under discussion to show the FSA and even document the terms of reference for the discussion and the actions you plan to take on everything from TCF to complaint handling and provider product changes and impact on customer suitability.
Read FSA newsletters on their website because your firm will be measured against those standards later. Read widely in the trade press, go to trade events and seek out additional information on the network websites and Linked in, said Farr.
