FCA Compliance Monitoring Program Template

FCA Compliance Monitoring Program TemplateUnder the compliance arrangements of the FCA’s authorisation application guidance notes, the regulator specifies the minimum requirements a firm must have for documenting their compliance procedures.

The FCA specify that the Compliance Monitoring Programme (CMP) must be tailored to the business and take into account the type of regulated activity that the firm intends to carry out. The CMP must be submitted to the FCA during the authorisation application process to demonstrate what checks are carried out to ensure regulatory compliance.

 

Compliance Monitoring Programme

The FCA Compliance Monitoring Programme is an integral part of assessing compliance and demonstrates to the FCA what actions and checks a firms undertakes to assess, monitor and record their regulatory compliance. All mandatory compliance procedures must be ready for inspection by the FCA at any time and are also essential for preparing, completing and submitting the Compliance Monitoring Programme to the regulator.

The minimum compliance arrangements noted by the FCA include:

  • Scope of business
  • Complaint handling procedures
  • Financial crime and AML procedures & responsibilities
  • Skills, knowledge and expertise assessments
  • Information security and Business continuity
  • SMCR compliance & FIT assessments
  • Communication with customers
  • Record keeping and management information
  • Notifications to the FCA
  • Reporting requirements
  • Compliance with conduct of business rules (COBS & CONC)
  • Scope of service provided
  • Status disclosures
  • Conflicts of interest procedures
  • Reliance on others (outsourcing & supplier due diligence)
  • Protecting customers’ interests (TCF and Vulnerable Customers)
  • Distance marketing
  • Financial promotions
  • Appointed representatives
  • Customer identification procedures (due diligence)

The areas on the left are not an exhaustive list, but are the minimum standards expected by the FCA. Checks for ensuring compliance in these areas should be documented on the FCA Compliance Monitoring Program Template.

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The FCA Compliance Monitoring Program should cover: –

  • Which areas the compliance relates to
  • What actions or checks a firm performs to ensure ongoing compliance
  • The frequency of those checks
  • Who is responsible for carrying out the checks
  • What records of the checks are kept to confirm thet have taken place

Know Your Compliance Limited provide over 4500 organisations with policy templates for regulatory and legislative compliance across the UK. Our FCA Compliance Monitoring Program Template can be purchased as part of our audit and monitoring set or comes included in our complete FCA Compliance Manual. It offers an Excel template for firms to add their actions and checks based on the compliance procedures and arrangements that they have in place.

Further information on how to submit the CMP and what the FCA requires in it can be found on the FCA Compliance Authoirsation Guide.