She added: “Completing the application should be the final stage of the compliance process, not the beginning.”
One example in the High Street Firms Application Pack is question 57 which asks: “Will the firm be compliant with the senior management, systems and controls requirements from the date of authorisation?”
Firms must be able to give evidence that responsibilities have been parceled out to directors and senior managers. This should be recorded and those records kept up-to-date and on file for at least six years. Other more complex, systems and controls, include detailed requirements for compliance, risk assessment, internal audit and business strategy.
In Section H, other capital resource requirements include evidence of PII, client money handling, money laundering, training and competence and complaint handling by the time of authorisation.
Quiney said: “While it is likely that the FSA’s main supervisory focus will be on the bigger players, small brokers should not underestimate the implications of the new regulatory regime.”
According to RPC, the compliance burden on larger firms will be even greater. Firms worth over £1 million will have to complete either two or three annexes to the application pack, including detailed information about their business alongside an attached compliance plan or manual
