The issues were raised at Home Buyer Systems' conference for user firms and networks.
One major concern for compliance professionals is to establish comprehensive audit trails for the initial submission, amendments and sign off for financial promotions. Subsequent periodic checking then needs to be carried out that published promotions remain compliant throughout their shelf life. In addition, a facility is needed to keep records of databases used in the distribution of promotional material. Keeping a comprehensive record of all recommended changes to promotional material is particularly important for networks that sign off financial promotions for their ARs, as they are increasingly being asked to prove effective and frequent checking processes by the FSA.
Regarding the advice and sales process, emerging issues included the need to store proofs of customer ID in case it is needed should fraud (including money laundering) subsequently come to light. Self-certification continues to be an area that the FSA is concerned about, with advisers needing to produce evidence that they have tested the veracity of the customer’s self certified income, together with covering the issue of affordability. Home Buyer System already includes a compulsory budget planner to be completed for every self certification case. Interest only mortgages have also been the subject of recent FSA scrutiny, and a need was expressed for automatic reminders to re-contact interest-only customers regularly until evidence was on file that they had either converted to capital and interest payments or had put a savings vehicle in place.
Richard Angliss, managing director of Home Buyer Systems, commented: “As we draw nearer to the FSA’s 31 March deadline for all firms to fully implement TCF, everyone who is responsible for compliance within firms is anxious to make sure their systems can produce comprehensive proof that they are implementing the FSA’s Principle for Business number Six. In a principles-led regulatory regime, new issues will always be developing, and systems suppliers must have the capacity to respond quickly to new concerns. We are now building in new functionality to meet the additional needs identified by users Our regular user conferences and forums continue to provide vital feedback for us to keep delivering added value by way of systems updates to meet evolving compliance needs.”
