It said members should keep strict records of not only the type of Initial Disclosure Document (IDD) issued but also date stamp each IDD and archive it. To help with this, AMI is producing a 10-point guide to safe record-keeping, which is free to AMI members and can be downloaded from the AMI website: www.a-m-i.org.uk.
Chris Cummings, director of AMI, explained that intermediaries’ understanding of what the FSA was looking for would change as the regulator issued clarification and even changed the rules.
Cummings said: “While there is no doubt that an intermediary’s IDD will be correct when it is handed over, if a complaint arises later an Ombudsman will want to see a copy of it. As complaints can arise years after the initial meeting, unless firms have recorded the type of IDD issued, they could run into problems that risk undermining their defence against the complaint.”
John Gibson, general manager for risk and compliance at the Skipton Building Society, said: “It is our view that firms will be challenged in regulatory inspection visits to prove that they have not only issued an IDD but have done so in a compliant form. It will be important to be able to produce, on short notice, a reliable copy of the IDD issued to the customer. An inability to do so could cause unnecessary regulatory challenge and follow-up.”
