“…it (the Compliance Manual) is fantastic – as are your compliance books that I have already bought via Amazon.”
Claire Vine Operational Risk and Compliance Manager The Funding Corporation
OK, So Why Should I Need A Compliance Manual?
For any Compliance Officer, Compliance Manager or SMF16 who has been in the UK financial services industry for any more than a year, this document is important.
Critically they will know that one of the first documents that they, as well as all staff, have to read and attest to having done so, is the Company Compliance Manual.
Although this is not a regulatory requirement …
it is a regulatory expectation!
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There are a number of elements that the regulators not only expect to be documented, but also somewhere that explains the rationale behind the way company’s manager their risks. This would clearly be best summarised in a regulatory Operational or Compliance Manual.
The Regulator expects a firm to have a personalised and firm-specific compliance or operational manual pertinent to the firm and embedded within its procedures and culture.
Most on-line and centrally maintained manuals offered by some consultants are considered NOT to be personalised, firm specific ORrelevant enough to the individual firm.
As bought by IFAs, Private Banks, GI Brokers, Payment Providers, MSBs, EMIs, Portfolio and Asset Managers and others!
An additional function is where the firm can articulate how they expect the advisers to operate and the standards that they are expected to adhere to.
But what do I put in it?
Often Compliance Manuals can be used to document the sales process for adviser’s to follow including, for example, transaction only clients (there is no execution only anymore unless it is a self-trade).
There has to be clear distinction for specific procedures and, for example when to assess a client for appropriateness when they refuse to provide sufficient details for suitability.
We do not suggest you fill your Compliance Manual with just processes as it is a valuable place to store certain high level explanations of policies such as the Data Protection Act, Bribery Act, Outsourcing Policy and Whistleblowing protocols.
Additionally this invaluable document can be used to point to other company documents such as policies and forms or other constantly updated items such as the Anti-money Laundering and Terrorist Financing procedures or even areas such as your Approved Persons Policy or possibly additional changes from Euroland.
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Who Made This Manual?
Lee Werrell is a Chartered Fellow of the Chartered Institute of Securities and Investments (Chartered FCSI) which is a QCF Level 6 qualification, and he has drawn the document together for all to use. Lee has compiled the manual from interpreting the regulators requirements and experience from setting up new banks, advising stockbrokers and fund managers as well as wealth managers and IFAs, CCA transition firms, payment services providers and other financial institutions. Lee has over 30 years experience in financial services and compliance.
See the Compliance Manager’s Guidebook & Reference HERE or on AMAZON
What Content is Valid?
The content of your Compliance Manual has to be relevant to be business concerned and accurate regarding procedures and sub-policies, as well as reader friendly. We do not update the manual or dictate to you what you should update (as it may not be relevant or pertinent to your business model) and therefore we do not charge update fees. We do not sit down and write your manual from scratch (an exercise that is expensive in both cost and management time).
Once purchased, the Compliance Manual is yours to updated and amended as you see fit, updating and amending what you need to on issues and areas that you feel are important.
We do not feel that keeping your manual updated year on year is beneficial to you as the FCA and PRA consider that The key to an effective the Compliance Manual is that it must be bespoke to the firm.
And don’t forget, our Template Compliance Manual is so flexible that has been bought by IFAs, Private Banks, GI Brokers, Payment Providers, MSBs, FinTEch, Portfolio and Asset Managers, stockbrokers (execution only and advisory), some foreign company’s with UK interests, but mainly domestic small to medium sized firms, including IFA Networks and even local council lending initiatives!
Just click on this graphic to see the PDF of what’s included!
Check out the video for the simplicity and logical layout of the manual and see the headings we list.
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The contents that are covered in the Compliance Manual covered (alphabetically) are: (new sections are italicised)
Advertising for New Business
Anti-Money Laundering
Breaches, Discipline & Enforcement
Bribery, Facilitation and Unethical Payments
Business Continuity
Client classification
Company introduction and areas of business
Company’s compliance structure
Complaints handling & procedure
Complaints Sample Logs (General, 3 Day & RFCs)
Compliance Monitoring
Conduct Risk implications
Conflicts of Interest
Controlled Functions and Governance
Customer Assets
Data Protection (GDPR)
Data Protection & Employees Rights
Dealing with Customers
Document Retention Policy
FCA/PRA Principles for Business
Financial Promotions
High Level Regulatory Requirements
Inducements/Gifts and Entertaining
Introduction and responsibilities of staff
Market Abuse & Insider Dealing
Notifications to the FCA/PRA
Order Execution Procedure
Outsourcing
Principles & Code of Practice for SMCR inc COCON
Record Keeping
Regulatory environment and Scope of permissions overview
Remuneration
Risk assessment
Senior Management Systems and Controls
Senior Staff/Management listing
Specific Permissions for company
Stewardship Code
Terms of Business
Trade Monitoring Procedure
Training & Competence
Transaction Reporting Requirements
Treating Customers Fairly (TCF) – Application
Treating Customers Fairly (TCF) – Overview
Version Control log
Whistle-blowing
Plus an extra section with ACTIVE hyperlinks(see below) to current rules and legislation, categorised for ease of your reference
Our Template Compliance Manual has over 140 pages of areas that are best concisely explained or stated in this central reference point in a logical and cumulative layout. This allows whole policies, or high level documentation to be used by new staff members as a earning tool, existing staff as a reference and everyone as a regulatory guideline and company standard.
TheActivelinks in the Bibliography take you to sections of the regulator’s handbooks and other relevant reference material
We designed it in this way as these documents are not written into your manual as hard copy, so whenever they are updated by the regulator, you always access the latest material.
The sections covered are;
Compliance Oversight and the Compliance Function,
Conduct of Business,
Sourcebook and Client Assets,
Regulatory Approach to Risk Management,
Compliance and Ethics,
Anti-Money Laundering &
PRA Links
You get a Fully Customisable Document with an editable Cover Sheet and Fully Editable Contents with a list of specific highlighted areas for you to make amendments appropriate to your company setup.
To anyone with a modicum of MS Word skill, the Table Of Contents is easily updateable with just three clicks of your mouse.
Our Compliance Manual is written in simple English, encapsulating the requirements in such a way that it enables Senior Management, Advisers and Administrative Staff to fully understand what the requirements are AND what they mean in practice as well as how you apply them to achieve and maintain compliance.
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Our Compliance Manuals can be purchased via PayPal and your copy will be sent to you within minutes (normally) as a Zip file with instructions on what to change. E-cheques take a longer period (up to 7 days).
Please make sure you check your spam/junk box in the next 5 minutes after purchase.
Once purchased, the Compliance Manual is yours to updated and amended as you see fit, updating and amending what you need to on issues and areas that you feel are important.
