The Priceof Breaching the FSA Principles   A CEI Compliance Information Presentation
The FSA A Principled RegulatorThe Financial Services Authority (FSA) issue Final Notices wheneverthey have disciplined or ...
The FSA A Principled RegulatorThe FSA’s Final Notice to CPP details that the firm wasfound to have breached Principles 3 (...
The FSA A Principled RegulatorWhilst the details are interesting and obviously relevantto the company’s either ignorance o...
The FSA Principles for Business1.   Integrity: A firm must conduct its business with integrity.2.   Skill, care and dilige...
The FSA Principles for Business7.  Communications with clients: A firm must pay due regard to the    information needs of ...
The FSA A Principled RegulatorNot only Firms are bound by these Principles andthere are a long list of people who have rea...
The FSA A Principled RegulatorAdditionally, if the recipient isfinancially embarrassed and any finewould cause financial h...
The FSA A Principled RegulatorThe cost of complying with theregulations may seemexpensiveand some even see it as a lostcos...
What Is This Presentation            This is a regulatory summary service            provided by CEI Compliance Limited, T...
So Who Are CEICompliance?                                          The Fastest Growing                                    ...
Areas of WorkingBecause of our reputation of                                     Areas of Workdiscretion and confidentiali...
Isn’t Bigger, Better?Generally, No.It’s usually just more expensiveFortunately, there are more positive alternatives tousi...
Dealing with a niche consultancyYou are always dealing with the principal when you aredealing with my firm. This means tha...
Dealing with a niche consultancyThere is more likelihood of your privacy andconfidentiality being observed with fewer peop...
Dealing with a niche consultancySince we handle fewer concurrent projects than larger firms,our attention is focused on th...
Dealing with a niche consultancyThe expertise that larger firms use is often white-labellingfor them by a pool of consulta...
And, additionallyThe benefits of dealing with the “ComplianceDoctor” and CEI Compliance is;A firm with experienced and qua...
What Makes Us Different?   Phase 1   We will conduct an initial appraisal at our cost             – only charging for expe...
Who Are Our Clients?                              text.  We have a wealth of Financial Services Experience, and  due to th...
Who Are Our Clients?   We also have a large   amount of experience in a   number of other fields and   industries within t...
Questions? More Information?            CEI Compliance Limited             www.cei-compliance-limited.co.uk               ...
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The price of breaching the fsa principles

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The Financial Services Authority (FSA) issue Final Notices whenever they have disciplined or censured a firm or individual for whatever reason.

The Principles are;
Integrity: A firm must conduct its business with integrity.
Skill, care and diligence: A firm must conduct its business with due skill, care and diligence.
Management and control: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
Financial prudence: A firm must maintain adequate financial resources.
Market conduct: A firm must observe proper standards of market conduct.
Customers' interest: A firm must pay due regard to the interests of its customers and treat them fairly.
Communications with clients: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.
Conflicts of interest: A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.
Customers: relationships of trust: A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgment.
Clients' assets: A firm must arrange adequate protection for clients' assets when it is responsible for them.
Relations with regulators: A firm must deal with its regulators in an open and cooperative way, and must disclose to the FSA appropriately anything relating to the firm of which the FSA would reasonably expect notice.

The cost of complying with the regulations may seem expensive
and some even see it as a lost cost,
however, if you fail to run your business compliantly due to ignorance, arrogance or some other reason be it personal, cultural or even political;
make sure you have plenty of spare cash in your savings account.

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The price of breaching the fsa principles

  1. 1. The Priceof Breaching the FSA Principles A CEI Compliance Information Presentation
  2. 2. The FSA A Principled RegulatorThe Financial Services Authority (FSA) issue Final Notices wheneverthey have disciplined or censured a firm or individual for whateverreason.In November 2012 the FSA imposed a £10.5 million fine on CardProtection Plan Limited (CPP) for the mis-selling of insuranceproducts.The firm has also agreed to pay redress to its affected customers andit estimates that this will amount to approximately £14.5m, however,this figure could change depending on how many customers respondto CPP’s contact exercise. The total cost to the firm of the FSA’sinvestigation is estimated to be £33.4m, which includes the fine,redress and the overall costs associated with the investigation. Call 0800 689 9 689
  3. 3. The FSA A Principled RegulatorThe FSA’s Final Notice to CPP details that the firm wasfound to have breached Principles 3 (Management andControl), 6 (Customers’ Interests) and 7 (Communicationswith Clients) of the regulator’s Principles for Businesses.CPP failed to treat its customers fairly and did not provideclear information to its customers:• CPP sold its Card Protection product by emphasising that customers would benefit from up to £100,000 worth of insurance cover – when this was not needed because customers were already covered by their banks; and• CPP overstated the risks and consequences of identity theft during sales of its Identity Protection product. Call 0800 689 9 689
  4. 4. The FSA A Principled RegulatorWhilst the details are interesting and obviously relevantto the company’s either ignorance or arrogance, the endresult was due to a failure of the FSA Principles, a list of11 time forged values that firms, even today still breachfairly consistently, and always at their cost.Earlier in the same week they also fined another firmwith a financial penalty of £412,000 in respect ofbreaches of Principle 3 (Management and Control),Principle 9 (Customers: Relationships of Trust) of theFSA’s Principles for Businesses (“the Principles”). So whatare these principles? Call 0800 689 9 689
  5. 5. The FSA Principles for Business1. Integrity: A firm must conduct its business with integrity.2. Skill, care and diligence: A firm must conduct its business with due skill, care and diligence.3. Management and control: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.4. Financial prudence: A firm must maintain adequate financial resources.5. Market conduct: A firm must observe proper standards of market conduct.6. Customers interest: A firm must pay due regard to the interests of its customers and treat them fairly. Call 0800 689 9 689
  6. 6. The FSA Principles for Business7. Communications with clients: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.8. Conflicts of interest: A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.9. Customers: relationships of trust: A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgment.10. Clients assets: A firm must arrange adequate protection for clients assets when it is responsible for them.11. Relations with regulators: A firm must deal with its regulators in an open and cooperative way, and must disclose to the FSA appropriately anything relating to the firm of which the FSA would reasonably expect notice. Call 0800 689 9 689
  7. 7. The FSA A Principled RegulatorNot only Firms are bound by these Principles andthere are a long list of people who have realisedthat regulatory censure can be costly, morerecently such as;October 2012Martin Edward Rigney £117,330 for failing tocomply with Statements of Principle 1, 2 and 7;John Blake £100,000 for failing to comply withPrinciple 3Graeham Stuart Sampson £17,850 for breachingPrinciple 6 Call 0800 689 9 689
  8. 8. The FSA A Principled RegulatorAdditionally, if the recipient isfinancially embarrassed and any finewould cause financial hardship then apublic censure is promulgated as inthe unrelated cases of ReverendCarmel Jones breaching Principle 1(integrity) and Raymond Wagner foralso breaching Principle 1. Call 0800 689 9 689
  9. 9. The FSA A Principled RegulatorThe cost of complying with theregulations may seemexpensiveand some even see it as a lostcost,however, if you fail to run yourbusiness compliantly due toignorance, arrogance or someother reason be it personal,cultural or even political;make sure you have plenty ofspare cash in your savingsaccount. Call 0800 689 9 689
  10. 10. What Is This Presentation This is a regulatory summary service provided by CEI Compliance Limited, The UK’s Fastest Growing Alternative Regulatory Consultancy We can only advise on the salient points in this summary and if you want further details then we would suggest you access the full document from the BBA Website at http://www.bba.org.uk/downloads/bba/St reamline_Consultation.pdf Call 0800 689 9 689
  11. 11. So Who Are CEICompliance? The Fastest Growing Alternative UK RegulatoryCEI Compliance have been providing Consultancyrisk and compliance services to allsizes of regulated firms from start-upbanks and FTSE100 companies to IFAsand small Wealth Managers. Provide a Discrete Service for Remedial and Proactive Risk & ComplianceThe key to our success is that thosewho need to know refer us to others.We are a well kept secret who placesconfidentiality and honesty as two of Have an Ultimatetheir highest values. Goal of Improving Our Client’s Position Big enough to be credible, Small enough to care Call 0800 689 9 689
  12. 12. Areas of WorkingBecause of our reputation of Areas of Workdiscretion and confidentiality we Remedial with NDAoperate under Non-DisclosureAgreements for roughly 2/3rds ofour work Governance with no NDAExternal to this the breakdown ofour work is roughly split with 50% 62%Risk & Compliance and 50%Governance. 21% 8% 9%CEI Also trade under ComplianceConsultant(www.complianceconsultant.org) andS166 Reports (www.S166reports.co.uk) Source: CEI Stats June 2012as separate businesses. Call 0800 689 9 689
  13. 13. Isn’t Bigger, Better?Generally, No.It’s usually just more expensiveFortunately, there are more positive alternatives tousing a niche consultancy compared to the Accentures,McKinseys or the big accountancy firms like Deloitte, E&Yetc.We not only consider that size doesn’t matter, but largesize can actually be a disadvantage in meeting yourneeds. Call 0800 689 9 689
  14. 14. Dealing with a niche consultancyYou are always dealing with the principal when you aredealing with my firm. This means that I, the MD, are therelationship manager and there is no junior partner to whomresponsibility will be transferred. There is no decreasedaccountability, no "hand-off" to a less-informed colleague. Ifyour interests are at stake continually, shouldn’t youreasonably expect my continual involvement?We can usually provide resources on a "just in time"basis. That is, our projects do not have to cover excessiveoverhead, such as multiple offices, large administrativebackup, recruiting, partner perks, etc. We are organised toefficiently provide everything that you, as the buyer needs, butnothing more than that which means that you are paying forvalue and results and only minimum overhead. Call 0800 689 9 689
  15. 15. Dealing with a niche consultancyThere is more likelihood of your privacy andconfidentiality being observed with fewer peopleworking on the project. We (and/or the few people wemight also involve) are constant which means that thereisn’t the need to sift through dozens of differingperceptions.We’re faster. We can respond to requests quickly, andreturn all calls within four hours which means to youthat there is no need to worry about a bureaucracy,delays and unknown people on the other end of thephone. Call 0800 689 9 689
  16. 16. Dealing with a niche consultancySince we handle fewer concurrent projects than larger firms,our attention is focused on the job at hand. This means thatyou don’t have to "compete" with another dozen or so of ourclients, which may be larger, paying more or are more time-demanding. We structure our work so that every clientreceives maximum attention.Your investment is controlled. There is no "meterrunning". We work for a fixed, value-based, project fee.Large firms can’t afford to do that as readily because of all thepeople involved and their own insistence on measuring theirsuccess by billable hours. We measure our success by clientobjectives reached, not in “time units”. Call 0800 689 9 689
  17. 17. Dealing with a niche consultancyThe expertise that larger firms use is often white-labellingfor them by a pool of consultants available in themarketplace at any one time. We select our consultantsfrom practising subject matter experts whichmeans that you obtain the same or better expertise forless money, because;Inevitably, we are less expensive. There areeconomies to using someone who can base their fees oneach situation and not on a pre-determined service scaleor need for reaching a practice quota. This means quitesimply better value to you. Call 0800 689 9 689
  18. 18. And, additionallyThe benefits of dealing with the “ComplianceDoctor” and CEI Compliance is;A firm with experienced and qualifiedconsultants;A firm that can apply changes and needs in acommon sense way that is practical andeffective;A firm that is considered and respected asindependent and reliable by the FSA;A firm that provides you with unfettered accessto the principle immediately and on demand; Call 0800 689 9 689
  19. 19. What Makes Us Different? Phase 1 We will conduct an initial appraisal at our cost – only charging for expenses Phase 2 We will make a proposal based on our appraisal with your outcomes and needs Phase 3 We will discuss the precise scope with you and provide you with a project price We will complete the work to your original Phase 4 scope and satisfaction Each proposal deserves to be as unique as a fingerprint
  20. 20. Who Are Our Clients? text. We have a wealth of Financial Services Experience, and due to the remedial and sensitive nature of our work forming over 60% of our business and that is conducted under a Non Disclosure Regime, we cannot demonstrate every client.
  21. 21. Who Are Our Clients? We also have a large amount of experience in a number of other fields and industries within the major utilities and even Local Authorities.
  22. 22. Questions? More Information? CEI Compliance Limited www.cei-compliance-limited.co.uk Call 0800 689 9 689 Email info@ceicompliance.co.uk

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