An FSMA Section 166 (S166) Skilled Persons Report request from the FSA can be a bombshell and extraordinarily expensive if you do not follow some simple rules and create a different mindset to most. This can work in a positive way and the costs over time will be negligible. Alternatively, you can avoid them completely.
Call us on 0207 097 1434 or Email on info@complianceconsultant.org
What is a FSMA Section 166 Skilled Persons Report?
A key part of the process is a Section 165 which is a written notice for specified documentation to be provided to the regulator for their assessment and review. This will sometimes provide you with an idea of what they are looking for:
Tip 1 You should get your files reviewed, preferably independently by a compliance consultancy at the same time, so as to prepare your firm for whatever may follow; which on occasions is nothing.
Reality Check – There is no smoke without fire
The Section 166 also has to be in writing and may, or may not carry with it a Draft Requirement Notice. This notice sets out the skilled person requirements; scope of the report, considerations regarding calculating recompense and redress if required and provide an inkling as to the purpose, if you read between the lines.
Tip 2 Compliance Consultants should be engaged to help you read between the lines. FCA/PRA “code” needs to be interpreted by a consultant experienced in the workings of the regulators.
Reality Check - You will probably not know what the regulators are driving at, it may not be what you think.
Call us on 0207 097 1434 or Email on info@complianceconsultant.org
Artificial intelligence and robotics are advancing rapidly. While this could make our lives more productive and convenient, it also risks disrupting labor markets as many existing jobs are automated. It is important that governments implement progressive policies around job retraining and basic income to help people adapt to coming advances in technology.
Concrete blocks are a common building material made of a mixture of cement, sand, gravel, and water that is poured into molds and cured. They are stacked with mortar to form walls and other structures. Early blocks were made by hand but are now mass produced in automated plants capable of producing thousands per hour through a process of mixing, molding, curing, and packaging. Modern blocks come in standard sizes but also innovative designs for specialized applications like water resistance.
Dick Sheppard presentation for the Quality Leadership Network at the FDA Los Angeles on September 22, 2016 about monitoring product during storage and shipping to comply with FSMA.
FDA hosted three webinars after the release of the Food Safety Modernization Act (FSMA) Final Rules on Preventive Controls. These rules will set new safety requirements for facilities that manufacture, process, pack or hold human food and animal food.
Understand the differences and how a combined HACCP & HARPC plan can be produced. Includes a free pdf which compares the HACCP principles to the Preventive Control Rule and BRC for Food Safety.
Trust, but Verify - Tips & Tools for FSMA's Foreign Supplier VerificationTraceGains
The FDA’s Food Safety Modernization Act (FSMA) rule on Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals is now final, and compliance dates for some businesses begin in 18 months. To help the food supply chain prepare, TraceGains’ will zero-in on the FSVP in its upcoming webinar: “Trust, but Verify – Tips and Tools for Foreign Supplier Verification (FSV).”
TraceGains will host FDA attorney Marc Sanchez as its guest speaker for the webinar. The session is designed to give an overview of the key provisions and tips and tools you can use to simplify compliance with the new requirements and establish a world-class FSVP.
Specifically, the webinar will cover:
Examining your current supplier program and how to identify gaps in hazard analysis;
What the FDA says about electronic record-keeping for FSV;
What involvement is expected from the executive and management level;
Third-party verification of foreign suppliers;
Risk management best practices for FSV; and,
Tips & tools to simplify compliance with FSV.
Artificial intelligence and robotics are advancing rapidly. While this could make our lives more productive and convenient, it also risks disrupting labor markets as many existing jobs are automated. It is important that governments implement progressive policies around job retraining and basic income to help people adapt to coming advances in technology.
Concrete blocks are a common building material made of a mixture of cement, sand, gravel, and water that is poured into molds and cured. They are stacked with mortar to form walls and other structures. Early blocks were made by hand but are now mass produced in automated plants capable of producing thousands per hour through a process of mixing, molding, curing, and packaging. Modern blocks come in standard sizes but also innovative designs for specialized applications like water resistance.
Dick Sheppard presentation for the Quality Leadership Network at the FDA Los Angeles on September 22, 2016 about monitoring product during storage and shipping to comply with FSMA.
FDA hosted three webinars after the release of the Food Safety Modernization Act (FSMA) Final Rules on Preventive Controls. These rules will set new safety requirements for facilities that manufacture, process, pack or hold human food and animal food.
Understand the differences and how a combined HACCP & HARPC plan can be produced. Includes a free pdf which compares the HACCP principles to the Preventive Control Rule and BRC for Food Safety.
Trust, but Verify - Tips & Tools for FSMA's Foreign Supplier VerificationTraceGains
The FDA’s Food Safety Modernization Act (FSMA) rule on Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals is now final, and compliance dates for some businesses begin in 18 months. To help the food supply chain prepare, TraceGains’ will zero-in on the FSVP in its upcoming webinar: “Trust, but Verify – Tips and Tools for Foreign Supplier Verification (FSV).”
TraceGains will host FDA attorney Marc Sanchez as its guest speaker for the webinar. The session is designed to give an overview of the key provisions and tips and tools you can use to simplify compliance with the new requirements and establish a world-class FSVP.
Specifically, the webinar will cover:
Examining your current supplier program and how to identify gaps in hazard analysis;
What the FDA says about electronic record-keeping for FSV;
What involvement is expected from the executive and management level;
Third-party verification of foreign suppliers;
Risk management best practices for FSV; and,
Tips & tools to simplify compliance with FSV.
Imminent Labeling Changes: A TraceGains Webinar with Food DirectionsTraceGains
If you have any questions or comments, please send them to connect@tracegains.com. We look forward to hearing from you.
Meeting Description:
Consumers are often confused by food labels. Yet the entire food production industry is facing proposed labeling changes that can affect packaging design, ingredient choices, sourcing decisions, and so on. Many of these pending requirements could add even more confusion in the consumer marketplace.
Join us for a webinar with food policy expert Beth Johnson, MS, RD, founder and principal of Food Directions LLC, a boutique government relations firm headquartered in Washington, D.C. Johnson will discuss imminent labeling initiatives including:
-Genetically modified organism labeling debates
-Nutrition facts panel reform
-Gluten free labeling
-Menu and vending labeling
Learn what your company or organization can anticipate in terms of content and timing and how it can begin to prepare for the many changes ahead.
About Food Directions:
Food Directions operates at the intersection where public affairs meets food policy. With a thorough understanding of the interconnectedness of the legislative and regulatory process, Food Directions follows all issues related to agriculture, food safety, and nutrition policy at the federal, state, and international level. Headquartered in Washington, with deep relationships within federal agencies like Food and Drug Administration (FDA) and United States Department of Agriculture (USDA), and on Capitol Hill, Food Directions is plugged into the ever-changing dynamic.
Chill Out About FSMA - It's Complex, but it's Not Rocket ScienceTraceGains
Nervous about FSMA? With such sweeping changes to the food safety landscape, it’s only natural to be a little nervous. Especially when you consider the voluminous pages of regulatory language, several rules are still pending, and FDA's plan to develop and offer training to industry is still unfolding. In response to these challenges, TraceGains has developed a new webinar series on FSMA readiness with FDA attorney Marc Sanchez to help make the tasks ahead a little less daunting.
The webinar “Chill Out about FSMA - It’s Complex, but it’s Not Rocket Science,” is designed to give an overview of FSMA's key provisions and the implementation timeline. Specifically, guest speaker Marc Sanchez will:
Interpret the rules and guidance published FDA on assembling a qualified food safety team;
Discuss how to analyze exiting quality and safety systems and identify gaps; and,
Offer strategies to document training and implementation of a FSMA-compliant food safety plan.
Preparing for New FSMA Preventive Controls RegulationsAlchemy Systems
FDA's current deadline for publishing the final rules for preventative controls for is quickly approaching. Find out what your company needs to know to prepare for these new regulatory requirements for FDA-regulated processors. This presentation provides an overview of preventative controls requirements under the Food Safety Modernization Act (FSMA), what is HARPC, and how to make the HACCP to HARPC conversion, as well as reassessing food safety plans for compliance and effectiveness.
Under FSMA, each human or animal food processing facility will need a “Preventive Controls Qualified Individual” (PCQI) to oversee or conduct preparation of the food safety plan, validation of the preventive controls, review of records, and reanalysis of the food safety plan.
During TraceGains' January FSMA Club webinar, TraceGains will host FDA attorney Marc Sanchez to explain the PCQI requirement and clarify what sort of training and experience FDA expects the author of your food safety plan to have.
Specifically, the FSMA Club webinar will cover:
Who is covered by the HARPC requirement for a PCQI;
Who is responsible for developing a food safety plan;
Validation of preventative controls;
Reanalysis of the food safety plan; and,
Employees vs. a third-party serving as the PCQI.
This document provides information about the third edition of the book "HACCP: A Practical Approach" by authors Sara Mortimore and Carol Wallace. It has been updated from the previous 1998 edition to reflect current best practices in Hazard Analysis and Critical Control Point (HACCP) systems for food safety management. The foreword discusses the importance of effective food safety practices, regulations, and organizations, noting that food companies must currently take the lead role in ensuring food safety. The acknowledgements and about the authors sections provide biographies of contributors. The book is intended to be a resource for developing, implementing, and maintaining HACCP programs.
If you have any questions or comments, please send them to connect@tracegains.com. We look forward to hearing from you.
Meeting Description:
Allergens are the leading cause for recalls, causing significant consumer health issues, scrap costs, and sourcing conundrums. Join our discussion on Allergen Control Issues with specific emphasis on Label Control measures.
Failures can happen at multiple stages of the operation. Label sourcing, generation or package placement -- potentially resulting in undeclared allergens. Learn to identify points in the process where labels and packaging need to be verified. Verification activities involve personnel from research and development, art and graphic approval, purchasing, receiving, production, and quality.
Evaluate common pitfalls, such as those associated with material staging and handling of obsolete materials, which too often lead to undeclared allergen concerns reaching the marketplace. Learn about best practices in Label Control that you and your team can implement immediately.
About AIB International:
AIB International is a corporation founded by the North American wholesale and retail baking industries in 1919 as a technology transfer center for bakers and food processors. The original mission of the organization was to "put science to work for the baker," and that basic theme is still central to all of the programs, products, and services provided by AIB to baking and general food production industries worldwide.
Although AIB's history has been traditionally linked with North American wholesale and retail baking, the Institute currently serves many segments of the food processing, distribution, foodservice, and retail industries worldwide.
Today's AIB is well-positioned in the following areas:
-Audit Services
-Food Safety Education
-School of Baking
-Research and Technical Services
This document discusses Hazard Analysis and Critical Control Points (HACCP), a food safety management system. It outlines the 7 principles of HACCP including conducting a hazards analysis, determining critical control points, establishing critical limits, monitoring systems, corrective actions, verification procedures, and documentation. The document also provides examples of food hazards and applies HACCP to a process flow map showing purchase, delivery, storage, preparation, cooking, food holding, and service.
Social Media, or website, one of the biggest questions people always ask is, to get onto Google page 1, or to get a good google ranking, what is the ideal length of things online. As things vary from URLs to blog posts, podacasts to videos the only answer is quite simply everything online should be long enough to convey the message and no longer. Social media posts are awash with way too much information and websites go overboard with cramming too much in, making for poor SEO and bad experiences, therefore not converting. Too much and it looks cheap. Too little and it doesn't raise interest. More details are at http://letstalksocialmedia.co
Most Employees Consider Their Private And Work Lives To Be Totally Separate, But Social Media and Social Networking Has Silently And Effectively Bridged That Gap And Blurred That Distinction.
No matter how “separate” a person’s social accounts may seem to be, there will ultimately be someone, somewhere that will link-up that person to your organisation or firm.
Social Media Policy Template http://wp.me/p4RKCt-5P
The document provides tips for senior management at regulated firms that have been issued a Section 166 report by the FCA, advising them to hire an independent compliance consultant to help prepare and navigate the process, as the investigation can be costly and the FCA's objectives may not be clear. It warns that the FCA-appointed auditors will conduct a thorough review and firms should not see it as a fight, and that cheaper consultants may not provide a comprehensive or value analysis. Proper preparation by an experienced compliance consultant can help firms understand the FCA's perspective and significantly reduce costs.
Video marketing is an increasingly important trend. It can increase engagement on social media by 100% and the chances of getting a top Google search ranking by 53 times. Viewers spend an average of 2 extra minutes on websites with videos and 65% are more likely to visit the site and make purchases after viewing videos. The document recommends businesses utilize video for marketing through infographics, product demos, content marketing and more to boost clicks, exposure, engagement and conversions.
Alex is a Compliance Director who has a number of issues. He finds an affordable, professional and discrete answer to his regulatory problems with a niche consultant, Compliance Consultant (tel 020 7097 1434)
The UK Regulators (FCA/PRA) are introducing a revised Senior Manager's Regime, taking over from the existing Approved Person's regime in June 2015. This gives you a high level overview and next steps to take to ensure your firm is ready.
Conduct Risk. Assessing risk and identifying cultural drivers for clear defin...Compliance Consultant
Conduct Risk is sweeping the financial services world and catching many risk manager out as there is still a lack of understanding.
Our Compliance Manual is available at http://bit.ly/ComplianceManualTemplate
Risk management need to determine the corporate risk philosophy and appetite. To assess or understand the risk philosophy, try to comprehend the organisation's culture, values and environment. The way business operations are conducted on a daily basis and the organisation’s strategy are typically good indicators where you can find the company risk philosophy. Assess whether business has an aggressive, innovative, typical or conservative attitude towards risks for achieving business goals.
Risk appetite is simply the amount of risk which the organisation is willing to take to undertake business activities and achieve the business objectives, where Conduct Risk is concerned this has to include good customer outcomes. A simple question to ask the board of members could be “What amount of reported mismanagement or public uproar would make you uncomfortable if it appeared in the business newspapers?”
Consolidate the various risk exposures from the risk department's identified risks and present them to the board. Finally, assess whether the company’s internal perception and rhetoric on risk philosophy and appetite are consistent with the board and other stakeholder's viewpoints. Realign the two where required to prepare the annual strategy.
Build Your Framework.
Setting Conduct Risk Appetite. Assessing risk and identifying cultural driver...Compliance Consultant
Conduct Risk is sweeping the financial services world and catching many risk manager out as there is still a lack of understanding.
Risk management need to determine the corporate risk philosophy and appetite. To assess or understand the risk philosophy, try to comprehend the organisation's culture, values and environment. The way business operations are conducted on a daily basis and the organisation’s strategy are typically good indicators where you can find the company risk philosophy. Assess whether business has an aggressive, innovative, typical or conservative attitude towards risks for achieving business goals.
Risk appetite is simply the amount of risk which the organisation is willing to take to undertake business activities and achieve the business objectives, where Conduct Risk is concerned this has to include good customer outcomes. A simple question to ask the board of members could be “What amount of reported mismanagement or public uproar would make you uncomfortable if it appeared in the business newspapers?”
Consolidate the various risk exposures from the risk department's identified risks and present them to the board. Finally, assess whether the company’s internal perception and rhetoric on risk philosophy and appetite are consistent with the board and other stakeholder's viewpoints. Realign the two where required to prepare the annual strategy.
Reducing regulatory capital by instigating risk management system and operati...Compliance Consultant
After assessing the risk management operation of a FTSE 100 company we soon identified that Operational Risk Management needed augmenting on their global risk framework. After 10 months work the savings were reflected in the reduction of regulatory capital requirements of over 18% (almost £100M).
Operational risk and risk management across multi-jurisdictions for internati...Compliance Consultant
A multi-jurisdictional banking group needed their Operational Risk Framework (designed by their parent company) to be rolled out and training given n risk reporting.
Increasing your chances of success by engaging with a niche consultancyCompliance Consultant
Fortunately, there are more positive alternatives to using a smaller consultancy compared to the Accentures, McKinseys or the big accountancy firms like Deloitte, E&Y etc. We not only consider that size doesn’t matter, but large size can actually be a disadvantage in meeting your needs.
The FSA published CP12/2 in January 2012setting out some of its proposals for changes to the considerable and substantive content of the Listing Rules; Prospectus Rules; and Disclosure Rules and Transparency Rules which it identified as being necessary for change to ensure that the operational effectiveness of the Listing Regime is maintained. The changes sought to ensure that the Rules properly reflect recent changes in contemporary market practices and so would allow the UK Listing Authority (UKLA) to continue to meet its objectives.
This consultation paper raised some wider issues concerning the nature of the premium listing standard and undertook, dependant upon responses, consideration to developing specific options or proposals for discussion in a further paper.
The Financial Services Authority (FSA) issue Final Notices whenever they have disciplined or censured a firm or individual for whatever reason.
In November 2012 the FSA imposed a £10.5 million fine on Card Protection Plan Limited (CPP) for the mis-selling of insurance products.
Whilst the details are interesting and obviously relevant to the company’s either ignorance or arrogance, the end result was due to a failure of the FSA Principles, a list of 11 time forged values that firms, even today still breach fairly consistently, and always at their cost.
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.
Imminent Labeling Changes: A TraceGains Webinar with Food DirectionsTraceGains
If you have any questions or comments, please send them to connect@tracegains.com. We look forward to hearing from you.
Meeting Description:
Consumers are often confused by food labels. Yet the entire food production industry is facing proposed labeling changes that can affect packaging design, ingredient choices, sourcing decisions, and so on. Many of these pending requirements could add even more confusion in the consumer marketplace.
Join us for a webinar with food policy expert Beth Johnson, MS, RD, founder and principal of Food Directions LLC, a boutique government relations firm headquartered in Washington, D.C. Johnson will discuss imminent labeling initiatives including:
-Genetically modified organism labeling debates
-Nutrition facts panel reform
-Gluten free labeling
-Menu and vending labeling
Learn what your company or organization can anticipate in terms of content and timing and how it can begin to prepare for the many changes ahead.
About Food Directions:
Food Directions operates at the intersection where public affairs meets food policy. With a thorough understanding of the interconnectedness of the legislative and regulatory process, Food Directions follows all issues related to agriculture, food safety, and nutrition policy at the federal, state, and international level. Headquartered in Washington, with deep relationships within federal agencies like Food and Drug Administration (FDA) and United States Department of Agriculture (USDA), and on Capitol Hill, Food Directions is plugged into the ever-changing dynamic.
Chill Out About FSMA - It's Complex, but it's Not Rocket ScienceTraceGains
Nervous about FSMA? With such sweeping changes to the food safety landscape, it’s only natural to be a little nervous. Especially when you consider the voluminous pages of regulatory language, several rules are still pending, and FDA's plan to develop and offer training to industry is still unfolding. In response to these challenges, TraceGains has developed a new webinar series on FSMA readiness with FDA attorney Marc Sanchez to help make the tasks ahead a little less daunting.
The webinar “Chill Out about FSMA - It’s Complex, but it’s Not Rocket Science,” is designed to give an overview of FSMA's key provisions and the implementation timeline. Specifically, guest speaker Marc Sanchez will:
Interpret the rules and guidance published FDA on assembling a qualified food safety team;
Discuss how to analyze exiting quality and safety systems and identify gaps; and,
Offer strategies to document training and implementation of a FSMA-compliant food safety plan.
Preparing for New FSMA Preventive Controls RegulationsAlchemy Systems
FDA's current deadline for publishing the final rules for preventative controls for is quickly approaching. Find out what your company needs to know to prepare for these new regulatory requirements for FDA-regulated processors. This presentation provides an overview of preventative controls requirements under the Food Safety Modernization Act (FSMA), what is HARPC, and how to make the HACCP to HARPC conversion, as well as reassessing food safety plans for compliance and effectiveness.
Under FSMA, each human or animal food processing facility will need a “Preventive Controls Qualified Individual” (PCQI) to oversee or conduct preparation of the food safety plan, validation of the preventive controls, review of records, and reanalysis of the food safety plan.
During TraceGains' January FSMA Club webinar, TraceGains will host FDA attorney Marc Sanchez to explain the PCQI requirement and clarify what sort of training and experience FDA expects the author of your food safety plan to have.
Specifically, the FSMA Club webinar will cover:
Who is covered by the HARPC requirement for a PCQI;
Who is responsible for developing a food safety plan;
Validation of preventative controls;
Reanalysis of the food safety plan; and,
Employees vs. a third-party serving as the PCQI.
This document provides information about the third edition of the book "HACCP: A Practical Approach" by authors Sara Mortimore and Carol Wallace. It has been updated from the previous 1998 edition to reflect current best practices in Hazard Analysis and Critical Control Point (HACCP) systems for food safety management. The foreword discusses the importance of effective food safety practices, regulations, and organizations, noting that food companies must currently take the lead role in ensuring food safety. The acknowledgements and about the authors sections provide biographies of contributors. The book is intended to be a resource for developing, implementing, and maintaining HACCP programs.
If you have any questions or comments, please send them to connect@tracegains.com. We look forward to hearing from you.
Meeting Description:
Allergens are the leading cause for recalls, causing significant consumer health issues, scrap costs, and sourcing conundrums. Join our discussion on Allergen Control Issues with specific emphasis on Label Control measures.
Failures can happen at multiple stages of the operation. Label sourcing, generation or package placement -- potentially resulting in undeclared allergens. Learn to identify points in the process where labels and packaging need to be verified. Verification activities involve personnel from research and development, art and graphic approval, purchasing, receiving, production, and quality.
Evaluate common pitfalls, such as those associated with material staging and handling of obsolete materials, which too often lead to undeclared allergen concerns reaching the marketplace. Learn about best practices in Label Control that you and your team can implement immediately.
About AIB International:
AIB International is a corporation founded by the North American wholesale and retail baking industries in 1919 as a technology transfer center for bakers and food processors. The original mission of the organization was to "put science to work for the baker," and that basic theme is still central to all of the programs, products, and services provided by AIB to baking and general food production industries worldwide.
Although AIB's history has been traditionally linked with North American wholesale and retail baking, the Institute currently serves many segments of the food processing, distribution, foodservice, and retail industries worldwide.
Today's AIB is well-positioned in the following areas:
-Audit Services
-Food Safety Education
-School of Baking
-Research and Technical Services
This document discusses Hazard Analysis and Critical Control Points (HACCP), a food safety management system. It outlines the 7 principles of HACCP including conducting a hazards analysis, determining critical control points, establishing critical limits, monitoring systems, corrective actions, verification procedures, and documentation. The document also provides examples of food hazards and applies HACCP to a process flow map showing purchase, delivery, storage, preparation, cooking, food holding, and service.
Social Media, or website, one of the biggest questions people always ask is, to get onto Google page 1, or to get a good google ranking, what is the ideal length of things online. As things vary from URLs to blog posts, podacasts to videos the only answer is quite simply everything online should be long enough to convey the message and no longer. Social media posts are awash with way too much information and websites go overboard with cramming too much in, making for poor SEO and bad experiences, therefore not converting. Too much and it looks cheap. Too little and it doesn't raise interest. More details are at http://letstalksocialmedia.co
Most Employees Consider Their Private And Work Lives To Be Totally Separate, But Social Media and Social Networking Has Silently And Effectively Bridged That Gap And Blurred That Distinction.
No matter how “separate” a person’s social accounts may seem to be, there will ultimately be someone, somewhere that will link-up that person to your organisation or firm.
Social Media Policy Template http://wp.me/p4RKCt-5P
The document provides tips for senior management at regulated firms that have been issued a Section 166 report by the FCA, advising them to hire an independent compliance consultant to help prepare and navigate the process, as the investigation can be costly and the FCA's objectives may not be clear. It warns that the FCA-appointed auditors will conduct a thorough review and firms should not see it as a fight, and that cheaper consultants may not provide a comprehensive or value analysis. Proper preparation by an experienced compliance consultant can help firms understand the FCA's perspective and significantly reduce costs.
Video marketing is an increasingly important trend. It can increase engagement on social media by 100% and the chances of getting a top Google search ranking by 53 times. Viewers spend an average of 2 extra minutes on websites with videos and 65% are more likely to visit the site and make purchases after viewing videos. The document recommends businesses utilize video for marketing through infographics, product demos, content marketing and more to boost clicks, exposure, engagement and conversions.
Alex is a Compliance Director who has a number of issues. He finds an affordable, professional and discrete answer to his regulatory problems with a niche consultant, Compliance Consultant (tel 020 7097 1434)
The UK Regulators (FCA/PRA) are introducing a revised Senior Manager's Regime, taking over from the existing Approved Person's regime in June 2015. This gives you a high level overview and next steps to take to ensure your firm is ready.
Conduct Risk. Assessing risk and identifying cultural drivers for clear defin...Compliance Consultant
Conduct Risk is sweeping the financial services world and catching many risk manager out as there is still a lack of understanding.
Our Compliance Manual is available at http://bit.ly/ComplianceManualTemplate
Risk management need to determine the corporate risk philosophy and appetite. To assess or understand the risk philosophy, try to comprehend the organisation's culture, values and environment. The way business operations are conducted on a daily basis and the organisation’s strategy are typically good indicators where you can find the company risk philosophy. Assess whether business has an aggressive, innovative, typical or conservative attitude towards risks for achieving business goals.
Risk appetite is simply the amount of risk which the organisation is willing to take to undertake business activities and achieve the business objectives, where Conduct Risk is concerned this has to include good customer outcomes. A simple question to ask the board of members could be “What amount of reported mismanagement or public uproar would make you uncomfortable if it appeared in the business newspapers?”
Consolidate the various risk exposures from the risk department's identified risks and present them to the board. Finally, assess whether the company’s internal perception and rhetoric on risk philosophy and appetite are consistent with the board and other stakeholder's viewpoints. Realign the two where required to prepare the annual strategy.
Build Your Framework.
Setting Conduct Risk Appetite. Assessing risk and identifying cultural driver...Compliance Consultant
Conduct Risk is sweeping the financial services world and catching many risk manager out as there is still a lack of understanding.
Risk management need to determine the corporate risk philosophy and appetite. To assess or understand the risk philosophy, try to comprehend the organisation's culture, values and environment. The way business operations are conducted on a daily basis and the organisation’s strategy are typically good indicators where you can find the company risk philosophy. Assess whether business has an aggressive, innovative, typical or conservative attitude towards risks for achieving business goals.
Risk appetite is simply the amount of risk which the organisation is willing to take to undertake business activities and achieve the business objectives, where Conduct Risk is concerned this has to include good customer outcomes. A simple question to ask the board of members could be “What amount of reported mismanagement or public uproar would make you uncomfortable if it appeared in the business newspapers?”
Consolidate the various risk exposures from the risk department's identified risks and present them to the board. Finally, assess whether the company’s internal perception and rhetoric on risk philosophy and appetite are consistent with the board and other stakeholder's viewpoints. Realign the two where required to prepare the annual strategy.
Reducing regulatory capital by instigating risk management system and operati...Compliance Consultant
After assessing the risk management operation of a FTSE 100 company we soon identified that Operational Risk Management needed augmenting on their global risk framework. After 10 months work the savings were reflected in the reduction of regulatory capital requirements of over 18% (almost £100M).
Operational risk and risk management across multi-jurisdictions for internati...Compliance Consultant
A multi-jurisdictional banking group needed their Operational Risk Framework (designed by their parent company) to be rolled out and training given n risk reporting.
Increasing your chances of success by engaging with a niche consultancyCompliance Consultant
Fortunately, there are more positive alternatives to using a smaller consultancy compared to the Accentures, McKinseys or the big accountancy firms like Deloitte, E&Y etc. We not only consider that size doesn’t matter, but large size can actually be a disadvantage in meeting your needs.
The FSA published CP12/2 in January 2012setting out some of its proposals for changes to the considerable and substantive content of the Listing Rules; Prospectus Rules; and Disclosure Rules and Transparency Rules which it identified as being necessary for change to ensure that the operational effectiveness of the Listing Regime is maintained. The changes sought to ensure that the Rules properly reflect recent changes in contemporary market practices and so would allow the UK Listing Authority (UKLA) to continue to meet its objectives.
This consultation paper raised some wider issues concerning the nature of the premium listing standard and undertook, dependant upon responses, consideration to developing specific options or proposals for discussion in a further paper.
The Financial Services Authority (FSA) issue Final Notices whenever they have disciplined or censured a firm or individual for whatever reason.
In November 2012 the FSA imposed a £10.5 million fine on Card Protection Plan Limited (CPP) for the mis-selling of insurance products.
Whilst the details are interesting and obviously relevant to the company’s either ignorance or arrogance, the end result was due to a failure of the FSA Principles, a list of 11 time forged values that firms, even today still breach fairly consistently, and always at their cost.
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.
Cp1230 FSA consultation paper summary: complaints against the regulatorsCompliance Consultant
This will be of interest to all firms and individuals that will come under the new UK regulators as regulated, registered or authorised.
Background
The FSA are currently required to make arrangements for the “investigation of complaints arising in connection with the exercise of, or failure to exercise, any of its functions (other than its legislative functions)” under the Financial Services and Markets Act 2000 (FSMA).
The latest version of the Financial Services Bill requires the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA), and the Bank of England to establish how they will investigate complaints against themselves.
The Bank of England and the Financial Services Authority (FSA) jointly published a 34-page Consultation Paper (CP) 12/30 entitled ‘Complaints against the regulators – (The Bank of England, Financial Conduct Authority and Prudential Regulation Authority)’, on 6 November 2012.
UCIS is an acronym for Unregulated Collective Investment Schemes and the term unregulated can lead to confusion with inexperienced investment advisers as well as clients.
Many perfectly normal and commonly understood Collective Investment Schemes (CIS) are sold to investors throughout the UK. These CIS are regulated and are authorised by the Financial Services Authority (FSA) or they may also be non-UK CIS that are recognised by the FSA. The official term of recognition enables overseas CIS to be marketed to the public in the UK and the FSA will only recognise an overseas scheme if certain specified criteria are met.
CIS are a type of pooled investment. This is an arrangement that enables a number of investors to 'pool' their assets and have these managed by an independent professional, such as a fund manager who will reduce risk by investing the pooled money in one or more types of asset. Most investment ‘funds’ are collective investment schemes.
Investments are often in gilts, bonds and quoted equities, but depending on the type of scheme can go further, such as into unquoted shares or property.
UK Financial Services are regularly visited by the FSA. The visit will include random interviews with fairly deep questions asked that, when taken as a whole, if they don't add up, will require further regulatory scrutiny.
We help companies prepare for these visits and explain what the FSA are looking for, how best to respond and how to keep up your end in a very intimidating process.
CEI Compliance is the UK's fastest growing regulatory consultancy and provides associate opportunities to consultants and cost effective value to financial services and other regulated companies.
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2. “… is like a car crash in slow motion, the right
compliance consultant is your ABS brakes.
You don’t know where you will end up but at
least you can steer through it!”
Tony Woodward
Chartered Fellow of the CISI
3. S166 Reports are often required by the
regulator on a single or sometimes multiple
subjects where they feel that the regulated
firm may have shortcomings or failings.
4. Tony Woodward, a former CEO of a city firm explains;
“Between November 2007 and June 2008 the City stock broking firm that I
presided over as CEO was visited by the FSA. What followed was a strong
attack by the regulator using a section 166, which cost in excess of
£500,000 to defend and an immeasurable cost in lost management time,
staff time and productivity. During this period the venom of the attack was
at times unfathomable, we engaged experts who in turn had ex-FSA staff
who seemed to be as stumped as we were about the regulator’s concerns
and objectives.”
5. Tony goes on to say, “Senior Management in regulated firms typically
believe they are doing the right thing and that they can explain to the
FSA why they do certain things and they will understand, they are very
highly mistaken. I do not work as a compliance consultant, I work with
senior managers on a peer-to-peer basis, sharing real life experience to
underline the genuinely valuable and rare advice I impart. I fully
understand and communicate to senior management how the FSA
want to see financial firms run and, in a macro view, the organisational
structures required to run effective compliance without creating
enormous compliance departments which drag on profitability.”
6. A key part of the process is a Section 165 which is a written notice for
specified documentation to be provided to the FCA for their assessment
and review. This will sometimes provide you with an idea of what they
are looking for.
Tip 1 You should get your files reviewed, preferably independently by
Compliance Consultant at the same time, so as to prepare your firm for
whatever may follow; which on occasions is nothing.
7. Reality Check – There is no smoke without fire
The Section 166 also has to be in writing and may, or may
not carry with it a Draft Requirement Notice. This notice
sets out the skilled person requirements; scope of the
report, considerations regarding calculating recompense
and redress if required and provide an inkling as to the
purpose, if you read between the lines.
8. Tip 2 Compliance Consultant should be engaged to help you read
between the lines. FCA code needs to be deciphered by a consultant experienced in
the workings of the FCA.
Reality Check - You may not know what FCA are driving at: it may not be what you
think.
Tip 3 Too often, advisers see this demand by the regulator as a personal slight
against them or their firm, the advice or the way their customer’s have
been treated.
9. If the discussions with the FCA have been focussed on the removal of your
permissions, then there will likely be advice issues. If threats have been
forthcoming regarding your continued trading as a whole, then there are likely
to be advice issues. However, if they have reviewed some files and have asked
for a sample to be reviewed by the “Skilled Person” as the subject of the
report, it is more than likely that there are systems and controls worries,
processes and procedures are not being followed either at all or consistently by
one or more of your staff.
10. You would also have been expected to have picked this up for yourself with your
ongoing monitoring plan. Areas that need reinforcement are not always obvious
to firm’s management and often needs independent views on systems and
controls.
Tip 4 Money spent on ensuring you are compliant, asking Compliance
Consultant to conduct a Compliance Health-Check now is a small fraction
of the costs of a S166.
Reality Check - During a S166, the FCA can summon your S166 consultant
and/or your auditor to attend their offices at your cost, whenever they wish
11. In 2008/2009 there were 56 Section 166 Reports completed costing a
total of £12,800,000. In 2010 -2011 the FSA ordered 95 FSMA S166
Skilled Person Reports for over £32.2M.
In 2012/13 year there were 113 S166 requests made and, costs ranged
from £6,475 to £40m, up by 465%, with the average cost in excess of
£1.56M each. Compare this to 2005/2006 when 18 reports were
completed and you will see the average number of cases and the costs
have escalated, mainly due to the big consultancies charging into the
area with their large teams of analysts and managers and partners.
12. Does the FSA have the right to appoint the big accountancy firms? The simple
answer is yes. Under S166 of FSMA 2000, the FSA can then nominate a person to
make a report who, in the authority’s view, has the skills necessary to make a report
on the matter concerned. Since April 2013 they now have a panel of firms set to
carry out this work.
This will mean that the costs are likely to be higher than before, but this can be
reduced considerably if you engage Compliance Consultant to carry out pre-S166
Preparation Planning with your firm. By having the right material ready
For the S166 Auditor, you can save tens of thousands of pounds.
13. Tip 5 The first thing that you need to do is issue a companywide
document preservation order, this ensures that everyone knows
not to conceal, delete, destroy, shred or in any way dispose of
any document as these may help you in your new circumstances.
Reality check - Under FSMA Section 177 it can be a criminal
offence if a person destroys any documents suspecting an
investigation.
14. There are several points to consider here, when preparing your list of Skilled Person nominees;
• Does the Consultancy have the right experience and skill set available? There is no point in using
a consultancy that has exclusively dealt with mortgage brokers or stockbrokers, if you are an IFA
firm.
• Is the Consultancy staffed by adequately qualified people with broad professional and life-sense
experience to provide a balanced view point?
• Is the Consultancy familiar with the FSA and their ways of working?
• Do they have the capacity to ramp up quickly if the FSA change the scope to require a project
based S166 for larger samples of cases or a more detailed analysis of your systems and
controls?
• Are they committed to professionalism, quality and accurate representation?
15. You only get a one chance with this. Do not treat the
bidding process like a car insurance quote. The cheapest is
just that, cheap and with no frills. Quite often single
consultant deals can be dangerous if their views are
jaundiced for some reasons or focussed in one particular
area. Without a sanity check of an external person they
could be inadvertently wandering off scope or not have
the support to reinforce their conclusions.
16. Tip 6 The FCA have appointed a panel of
respected and competent firms to act on
their behalf. These are the larger
consultancies that normally perform audit
and past business review work. This is a
more expensive but less time consuming
exercise than pre FCA.
17. Compliance Consultant are experienced, skilled, and
flexible. They always have a Quality Assurance and Project
Oversight who provides this sounding board and independent
viewpoint.
18. What happens when you get your allocated audit firm? Nobody likes
strangers poking about in their affairs for too long. You need to be prepared
for some uncomfortable news, but do not see it as a fight or justification
exercise, the auditors are there to obtain facts and evidence.
To do this work correctly, the files, systems and controls, policies and
governance, TCF or whatever aspect of review has been instructed has to
be done properly for your own sake.
Good preparation by Compliance Consultant can save you £££’s
19. Sit down and consider what would happen if you were new to your firm;
• How long would you want to understand the actual role you are going
to perform, with all the parameters, guidelines and limitations?
• How long would you want to read the company policies and compliance
manual?
• How long would it take you to write a report on ten or twenty files,
meticulously reviewed and appraised, ensuring all the evidence is noted
and identified?
20. • How long would it take to review that number of files properly, in detail,
objectively and commercially?
• Would you consider it fair to prevent the firm from adding in their response to
the report?
• How long would you like to spend on your report making sure that it fairly
represents the evidence you have seen and taken into account the holistic view
of each case?
21. Any external consultant who proposes to review more than 4
differing and varied cases per day (or 2 pension cases) from a
cold start, is misleading you or selling you short and making
uninformed decisions and conclusions that are sent to the
FCA on your behalf. What value is your business worth to you
over the next 12 months, five or even ten years?
22. Tip 7 It is worth getting a thorough and professional job done while you have the
chance, the cost of FCA scrutiny, defending your firm with appointed auditors and
lawyers the cost of fines or loss of livelihood is exponentially greater.
Reality check - After all, we are aware that if you choose well or choose badly, you
may only have one chance at this.
23. Price should be viewed in the round. If FSA decide you are guilty they
will ask for your costs in conducting the s166 and keep this in mind
when assessing the necessity for fines or the severity of fines. Therefore
often a high cost of the s166 can mean a reduction in ultimate fine; the
true cost of each purchasing decision will show itself over time. Cost
issues continue to present themselves over the useful life of the product
or service purchased, long after the purchase was actually made. If a
report becomes long standing company history, the cost is minimal: if
the company does not last the course, the cost far exceeds the price.
24. We do not keep staff around in case of suitable work and deploy them when and if
the need arises, we only use experienced and qualified compliance staff that are
specific to the project needs.
There will only be the required people working on the report that needs to be there
at any one time this focused approach keeps the cost to your firm at the level
required and nothing else.
Quality Assurance is always carried out independently and we will assist you with
the details when you are invited to provide management responses to the auditors
findings.
25. Once you appoint us, we will discuss with you and the FCA the scope of the scrutiny that
you face and iron out any anomalies and wrinkles. It has been known for the regulators
to get mixed up. We will identify the initial documents required as best we can and make
any preparations for the additional resource we may need to allocate so that they can
work immediately on day 1 to conduct their part of the work efficiently and effectively in
preparation for the S166 auditors.
Reality check - Compliance Consultant Consultants will always conduct a review of your
systems and controls before accepting you as a client (obviously an exception in a S166
exercise) and will provide you with recommendations for improvements.
26. “Had I had the guidance of an expert, with the experience I now have today, my
company and our board would have saved hundreds of thousands in costs, a
similar amount in lost productivity and we would have reduced our personal and
corporate risk.”
27. We have published EBooks to help UK Authorised firms in Compliance
and Risk areas. Our Compliance Managers Guidebook and Reference
Manual suits any small or medium sized enterprise.
Our Analysis & Risk Management System (ARMS™)
Book is also targeted at small and medium sized
enterprises helping them identify and evaluate, test
and report their risks in accordance with FSA
Handbook SYSC 4.1.1R