Introduction From Nikki Haworth

 July 2011
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Welcome to July's Pulse.

Good news for many is the base rate has remained at 0.50%. But for how much longer‌?

There are more and more fixed rates out there for those clients who believe this can't go on for many more months.

The best out there are 2 year fixes at 2.89% from Abbey and TMW.

We've definitely seen an increase in mortgage sales across the board. BTL has increased by 25% with BM's 4.29% fixed being very popular, purchases are up by 20% and remortgaging by 22%.

With the Coventry launching a 90%LTV 5 year fixed at 5.99% for First Time Buyers, Precise bringing out their Near Prime range and Kensington 's new products there are now options for more of your clients to remortgage or purchase.

How many times have you spoken to a client about Buildings and Contents insurance or Life cover and even done your research and prepared the quotes only to be told 'I've found it cheaper on the internet'!

The Financial Services Authority has written to 19 firms operating insurance price comparison websites about the fair treatment of consumers, and says many have designed their systems and controls to maximise revenue and have not paid sufficient regard to regulatory compliance. The regulator says consumers may be being mislead about the services they are receiving. A consumer may think they receive a quote on their individual circumstances when it's actually an illustrative quote on generic risk criteria.

It's time to fight back and promote your superior advice and service! Your clients want a policy that will pay out in the event of a claim and somewhere to turn to for help.

David's article this month also touches on good quality advice and service that will keep the Broker as a Key player in the Industry and the need to fight back against the High Street and the internet. Be proactive by calling up clients and build relationships!

Following the Conference many of you have tried your hand at new products such as commercial insurance and have had some positive results. The article from Berkeley Alexander gives you further information on this lucrative area of business.

And finally, congratulations to Matt Nickson of MN Associates , having taken advantage of the electronic Anti Money Laundering check available from Omnii he is the winner of the prize draw. A bottle of champagne is winging its way over to you.

Nikki

Word from the FSA

FSA propose changes to RMAR for RDR

To support supervision of adviser and consultancy charging rules, the FSA are proposing to incorporate additional data collection into the RMAR.

In the consultation paper CL11/08 (http://www.fsa.gov.uk/pubs/cp/cp11_08.pdf), the FSA set out their proposals, designed to support RDR rules coming into force on 31st December 2012.

The proposals are:

  • A new section (Section K) that requires firms to provide data on adviser charging revenue, payment method, client numbers and charging structures.
  • A new section (Section L) that requires all firms that provide services on GPPs to provide data on consultancy charging fees, payment method, employer client numbers and charging structures; and
  • Minor changes to Section B (profit and loss account) and Section G (training and competence) to reflect the new definitions of adviser charging, consultancy charging and independent and restricted advice.
These proposals, if accepted, would have no bearing on the timing, frequency or level of a firm’s current reporting requirements.

Twice a year, firms must provide to the FSA a complete report of complaints received. The FSA are proposing firms break down their complaints data to individual advisers, detailing the number of complaints, number of complaints upheld and amount of redress paid in the firm’s last reporting period. This is designed to allow the FSA view the complaints record of an adviser throughout their career.

The proposals include a requirement upon firms to notify the FSA if an adviser is subject to three or more complaints in a 12 month period, or an adviser is subject to a complaint with a claim of more than £5,000.

The FSA believe that the collection of this data will help them achieve their objective of establishing a resilient, effective and attractive investment market. It will be an important part of the FSA’s supervisory approach post 2012 to mitigate the risk of poor consumer outcomes.

A policy statement will be published in the second half of 2011, with the rules coming into effect on 31st December 2012.

The regulatory outlook for mortgage lenders

In a speech given by Sheila Nicoll, FSA Director of Conduct Policy at the Building Societies’ Association (BSA) Annual Conference, the regulatory outlook for mortgage lenders was described, as ‘constantly changing’.

On the topic of the Mortgage Market Review (MMR), Ms. Nicoll was keen to stress that they felt it was very important and that it is not the FSA’s intention to deny people who can afford mortgages from obtaining them. However, the FSA want affordability to be at the heart of all mortgage lending and both borrowers and lenders to act responsibly.

Ms Nicoll stated that “I want to emphasise again that we will not reach any final conclusions without fully considering their impact, taking the proposals both individually and in the aggregate. We will take into account the overall economic situation in determining the timing of new rules and we will only introduce any new rules when we think the mortgage market is healthy enough to absorb the changes. This will not be before 2012.”

Talking about conduct issues, Ms Nicoll confirmed that in recent years there has been a focus, particularly in the deposit taking world on prudential issues: capital and liquidity. Ms. Nicoll claimed it was ‘inevitable’ given the financial crisis, but confirmed this does not mean the FSA has been ignoring issues around how firms conduct business with consumers. The new consumer protection strategy launched in March 2010 was described as being involved in ‘an intensified focus on conduct issues in the retail market’, something the FSA expect will continue and deepen.

Ms. Nicoll claimed that the Government’s decision to reform the regulatory architecture around financial regulation was a clear signal that it wanted to make sure that both prudential and conduct issues are given clear focus and resource.

The speech confirmed that the Prudential Regulation Authority (PRA) will have a clear mandate to deal with the prudential regulation of deposit takers and insurance companies whilst the Financial Conduct Authority (FCA) will focus on conduct issues, as well as on markets and prudential regulation of intermediaries, investment firms and others.

Discussing the Conduct Business Unit and Prudential Business Unit, Ms. Nicoll saw no need for day-to-day interactions to change.

Ms. Nicoll confirmed that the FSA were in the process of arranging conferences which will set out in broad terms, the proposed approaches of each of the authorities and provoke a debate with interested parties.

Regarding the Retail Conduct Risk Outlook (RCRO) (which was covered in EQI’s March Newsletter), Ms. Nicoll said ‘our consumer protection strategy aims to pick up early any significant risks’. She went on to say the RCRO, first published in February, shares the FSA’s thinking on emerging risks and potential concerns.

The RCRO is seeking to look forward and identify risks and concerns on which the FSA may need to focus on in the future. Reference was made to unfair terms in mortgage contracts and treatment of mortgage customers in arrears.

Other potential concerns identified were the bundling of investment and fixed-term deposit products. Some bundles may lead to good outcomes to consumers, but also involve increased complexity for consumers and higher switching costs.

With the European Union changes and the creation of the European Supervisory Authorities (ESAs), Ms. Nicoll believes power is shifting from member states and authorities to new bodies. The focus has been on fixing what went wrong in the crisis, with particular emphasis on capital and other prudential aspects. There has been increased interest from the European Union in consumer protection issues, with the ESA having a specific consumer protection objective.

Ms. Nicoll stated the FSA believes waiting for the international community could take years, and for that reason they would move to strengthen protection immediately.

In her closing remarks, the FSA Director of Conduct Policy, reaffirmed the FSA’s commitment to working hard to ‘assess and address the multiple challenges’ the industry faces in the current changing climate.

Two FSA decisions referred to the Tribunal

The FSA published two decision notices for enforcement decisions that have been referred to the Upper Tribunal. These are the first decision notices to be published since the power was given to the FSA by Parliament in 2010.

Stuart Unwin and Derek Wright have referred their cases and will present their cases to the Tribunal, as will the FSA. After the Tribunal has determined the appropriate action for the FSA, the decision will be made public on its website.

The Tribunal can uphold, vary or cancel the FSA’s decision.

Mr. Unwin is being accused of failing to ensure that his firm had adequate systems and controls to ensure that occupational pension transfer advice given by his firm was suitable and signed off by a pension transfer specialist, despite a previous FSA warning about this.

Mr. Wright is accused of arranging for his wife to take on the FSA approved roles whilst he actually ran the small insurance brokerage. Mrs. Wright had no involvement in the running of the business at Moorgate and did not exercise her function as a director properly.

The FSA argue that Mr. Wright’s history, which involved him being disciplined by Lloyds of London in 2001, would have been very relevant had he directly applied for approved person status.

Forbearance and Impairment Provision

The FSA has set out in a document their findings following a prudential review of firms’ mortgage forbearance and impairment provisions processes. The document can be found on the FSA website here.

The review is focused on the prudential risk responsibilities of firms and thus on practices that impact on the loss risks of accounts (forbearance provided to support financial stress), the effective management of these risks and the mechanisms for their recognition and reporting. The FSA believe forbearance provided based on sound conduct principles provides for sound prudential management.

The guidance covers the following:

  • The provision of forbearance support for customers undergoing financial stress;
  • The recognition of impairments within the book through management committees and Board reporting; and
  • The disclosure of impairment and its recognition through loss provisions in external reporting.
The FSA says lenders that do not disclose the true impairment condition of individual loans in their books create a misleading picture of the performance of their books and so there is a market incentive to use increased forbearance.

Where firms are using techniques which materially change the cash flow of the mortgage, such as extending the term of the mortgage, transferring it to interest-only, or flexing the terms of the deal,
the FSA say they need to make sure they are doing so for the right reasons.

The FSA says that if these measures have an impact on the recognised arrears of the customer, either by stopping accounts going into arrears or reducing the severity of the arrears, the true underlying customer impairment is often not reported either internally through committee or board reporting or externally in accounts.

As part of the consultation, the FSA is proposing that firms do not put borrowers in a worse position than they already were, for example, by moving them to an interest only mortgage which would not raise their prospects of improving their financial situation.

It also wants firms to ensure processes are in place for the identification, reporting, monitoring and loss risk assessment of forbearance provided to those facing arrears. The consultation closed on the 14 June.

Included within the document were examples of good and poor practice covering:

  • The overall provision of forbearance to customers;
  • Where a capitalisation event takes place;
  • Where the customer is temporarily transferred or permanently converted onto interest only terms;
  • Where the mortgage term is being extended;
  • Where flexible terms facilities are being used;
  • Calculating overpayments where a drawdown facility is available;
  • Recognition of impairment in internal and external reporting;
For full details of the guidance and examples of good and poor practice please refer to the FSA Guide

 

Word From David Ewing

With many brokers reporting an increase in enquiries, this inevitably brings with it an increase in risk not only to the individual firm, but also the industry as a whole.


Understaffing for the medium to large firm will undoubtedly give rise for concern. The essential requirement of cost cutting over the past 3 years has meant that many firms have staffing levels at a minimum, and a sudden surge of business will without question put a strain on resources. The first thing to go as insufficient levels of staff try to cope with increased business levels will be the quality.

Very few firms in the current climate will be strong enough to finance additional administration support in advance of increased sales volume. Many will have to finance new staff from the increased revenue derived from the increase numbers.

The smaller broker is equally at risk. With many clients still trapped due to the removal of self certification mortgages, the temptation for brokers to be attracted to Fast Track mortgages as a way to help their clients, will in some instances be too great. Whilst several lenders are still very much in the market for this type of business, it is also very closely monitored by lender and FSA alike. If income cannot be proven.......!

The temptation to give the client the wrong advice when considering their financial circumstances and indebtedness can also be seen as an issue. For many clients, whilst a mortgage may seem the answer, and it pays the broker a commission, debt management plans including IVA's should be very much in the broker’s arsenal.

We now only have around a third of the brokers we had 3 years ago, and still a further decline expected as the FSA continues to root out the rouges.

We are now seeing the FSA advertising independent advice and Lenders increasing their advertising for direct business.

If the broker is to continue to play a key role in the industry, it is now more important than ever that as a community we maintain the professional standards and image we have worked so hard to achieve.

Taking shortcuts to maximise opportunities the higher loan to values and lower rates are starting to bring, or under preparing for increased business volumes can only lead to disaster.

There are more statistics and cross pollination of information between lender and regulator than ever before. To lose direction at this stage, when I genuinely believe we are on the home straight could be a grave error of judgement with terrible consequences.

With all kinds of talk and gossiping about MMR, RDR and the new European Directive the face of our market could change dramatically over the next 18 month and as brokers we are best placed to handle these changes. Let’s make sure we are around to maximise the benefits.

David

Mortgages News

Mortgage Arrears likely to rise

The Association of Mortgage Intermediaries (AMI) has released its latest Quarterly Economic Bulletin looking at the economy, housing and mortgage markets.

The Bulletin raises concerns over current trends in the UK economy and the likelihood of an increase in the number of people in long-term mortgage arrears due to predicted rises in unemployment and interest rates.

Robert Sinclair, Director of AMI, said: “There is an undeniable link between unemployment figures and those in long-term arrears.

“With the prospect of rising unemployment looming, there is now real concern that more people will find themselves in difficulty.

“The expectation of localised sharp price falls on the back of interest rate rises carries a significant short-term risk, but a squeezed supply means property should remain an attractive long-term investment and proves a strong market underpin.

Focussing on the positives, Mr Sinclair said: “demand for buy-to-let lending remains particularly strong and continues to offer investors long-term value.

“With lenders now returning to the market, greater competition is likely to further improve landlords’ prospects.”


Check IT

We are delighted to announce the winner of our prize draw!
Congratulations go to Matthew Nickson of MN Associates who has won a bottle of champagne.

Matthew has been taking advantage of the CheckIT system for the last few months a his ID and Anti Money Laundering verification system.

We are pleased that the CheckIT proposition continues to grow in popularity and is proving a real asset in creating client synergy and enabling the Broker/IFA to gain a full understanding of their clients credit position.
The product is an innovation in technology allowing the intermediary the opportunity to fully understand a client’s credit file with this instant online system that offers the following services;

Identity Client Verification and Anti Money Laundering Check.

Client Credit File Check

Combined Identity Client Verification/ Anti Money Laundering Check & Client Credit File Check.

Combined Identity Client Verification/ Anti Money Laundering Check/ Client Credit File Check and Property Valuation Check.

With an ever increasing emphasis on regulation and compliance, fully knowing your customer and understanding their credit profile is imperative and will enhance any business process and save you the intermediary both time and money.

Please see the attached document for further information.

To register and find out more please contact the office on 0845 371 3433 or email: info@ingard.co.uk

New criteria, new products, speedy decisions and first class service.

Following the analysis of our recent Near Prime broker and consumer survey, we have improved our criteria to help you place cases for your customers more easily. To complement the new criteria changes we have also launched a new range of attractive Home Owner products.
Criteria highlights include:
• Maximum defaults £5,000
• Maximum CCJs (both satisfied and unsatisfied) up to £2,500
• 1 Month's arrears in the last 12 months with up to 3 instances in the last 36 months
• Only defaults and CCJs recorded in the last 24 months used when assessing a case
Product highlights include:
• 2 Year Fixed and Tracker products
• Rates from 4.85%*
• Up to 80% LTV
• Some products with £250 cashback, refund of standard valuation and assessment fee and no ERCs

Get a decision on your case in minutes, login today and experience our speedy state of the art online mortgage system. Alternatively if you have a case you would like to discuss, contact one of our underwriters direct on 0800 116 4385 or your local BDM Claire Rankin (North) 07432 124167 and Sandra Cook (South) 07903 088941.

Visit www.precisemortgages.co.uk for full details on our Home Owner, BTL and Short Term Lending product ranges.
Exclusively yours,

Precise Mortgages
P.S Don't forget our 'Big Give Away'. For every case you submit to us which proceeds to valuation will earn you a gift for you or your customer. The Big Give Away includes reductions to product fees, £100 of additional procuration fee and many more exciting gifts.

 

Brilliant Mortgages

 

Insurance News

Lloyds drops PPI challenge

Lloyds Banking Group has withdrawn its support for the British Bankers’ Association’s (BBA) judicial review of payment protection insurance complaint-handling measures and set aside £3.2bn to compensate customers.

The provision set aside has caused the bank to report a loss of £3.5bn for the first three months of the year, compared with a £721m profit for the same period in 2010.

The judicial review was launched by the BBA in October 2010 and stems from a policy statement published by the FSA in August setting out a package of measures for firms to implement when dealing with PPI complaints.

The regulator estimated the cost to firms of complying with the measures could be up to £4.5bn and firms were told to implement the measures by December 1, 2010. But the BBA challenged the FSA’s policy statement, as well as guidance published by the Financial Ombudsman Service on its website, saying the measures were based on principles that are not acceptable in law. The High Court heard the case in January and ruled in favour of the FSA and FOS in April.

A Lloyds spokesman said: “We will no longer be participating in the BBA’s judicial review. We believe this draws a line under the issue. We have always said we wanted to provide certainty for our customers. Drawing a line under this issue does exactly that and is also in the interests of the long-term stability of our business.”

Lloyds accounted for more than a fifth of PPI-related complaints during the second half of last year – more than any other firm.

Michael Pilgrim, director of PPI claim management firm Randall and Vickers, said: “The Lloyds’ provision is the first accurate indication of just how widespread the misspelling of PPI policies was. For 10 years, consumers have been aggressively sold policies which were expensive, ineffective and, in a lot of cases, downright useless.”

The FSA welcomed the decision of the BBA to accept the High Court’s dismissal of their legal challenge.

The FSA confirmed that banks must get on with handling all PPI complaints and paying redress where appropriate.


LV=

Safe and Secure

Jason Berry - WORK SMART AND EARN MORE

Intermediaries do not need to work longer hours or adopt new behaviours in order to earn more income.

If working smart is an aim, two best practices often delivered by the minority should be considered by the majority;
A/ Turn previously ignored sales opportunities into revenue by revisiting your customers to offer new services
B/ Offer these additional services to ALL new customers.

Effective examples of above actions could see wealth management and investment advice offered to customers who only previously received mortgage or protection service whilst providing General Insurance solutions will ensure significant trail incomes are generated in an area where historic sales penetration has probably been low.

It is true that for those advisers wishing to control the customer sales process in its entirety, undertaking above actions may require new skills and qualifications but this up skilling or time investment does not need to be the only solution.

Setting up Introducer arrangements in specific business areas can be a smart way of maximising income and ensuring all customers receive a holistic sales experience – It can also be an effective way of keeping opportunistic competitors away from your clients.

I understand finding appropriate suppliers with similar ethics and customer experience values can be challenging but such businesses are in the marketplace, many with strong foundations and stretching ambitions.

Finding the right partner can be highly profitable and a worthwhile exercise – as an example 8 weekly referred General Insurance enquiries should generate 5 weekly sales which after 4 years equates to a £50k of annual income – Considering a different approach can be a sensible way of improving profitability without needing to work harder.

 

Aegon

 

Writing Policies in Trust

Following on from the trust analyser that was in the newsletter a few months ago, Aegon has launched a new area on their website designed to help brokers give added value to their clients by making sure their beneficiaries get the money that is intended for them.

Visit this link for more information.

 

Berkeley Alexander Business Insurance

At your recent Sales Conference we highlighted our Business Insurance service, which can help Ingard members to find the right cover, the right product, and the right price for all self-employed or corporate clients.

Utilising our knowledge of the lucrative commercial market, built up over 30 years, our services includes:-

  • A facility for you to obtain quotes and provide the advice yourself
  • A facility for you to simply introduce the client to us
  • A wide range of insurers and products areas
  • Initial & Renewal Commission of 15%*
Our BA Power quotation system accesses specialist insurers to quote on 8 products categories, namely :
  • Portfolio Landlord
  • PI and Public Liability
  • Commercial Premises
  • Shops
  • Pubs & Restaurants
  • Offices & Surgeries
  • Hotels & Guesthouses
  • Directors & Officers
Commission on any policies arranged via BA Power will be paid at up to 15% initial and renewal, whether you advise or introduce.

In addition to BA Power, we can also access the services of specialist partners within our group of companies, finding markets for :
  • Motor Fleet
  • Motor Traders
  • Taxi Fleets
  • High Risk/High Premium (£10k+) Commercial Combined Cover
  • Group Private Medical
Commission levels on this type of business will be advised at the time of quoting.

Advise or Introduce‌

Business insurance can be quite complex. If you’re not comfortable at the prospect of advising your client, then you can choose to Introduce. Advantages are :
  • No need to fact-find, quote or arrange
  • No concerns re product features or underwriting criteria
  • No regulatory responsibility or PI risk
  • You’ll still receive up to 15% commission on any business written

You can introduce clients to us online via www.baonline.co.uk , or by telephone on 01273 477784, and we will keep you updated at every stage of the process.

If you prefer to Fully Advise your client :

Call us on 01273 477784 and provide us with the information we’ll need to obtain quotes for you

So, you can now approach your self-employed and corporate clients in the certain knowledge that Berkeley Alexander will help you to secure what is often large premium business, without the need for you to become involved in the advisory process.

For more information call BA’s Business Development Manager, Alan Collinson, on 07900 910734 or email him at acollinson@baonline.co.uk

* Some of your clients will not fit the criteria for “BA Power”. If we need to utilise other markets, the commission rate will vary, but we will tell you at the time.

Select- Protect



News From The Ombudsman

Compensation for distress, inconvenience or other non-financial loss

The Financial Ombudsman Service has published their approach to awarding compensation.

When a consumer complaint is upheld, the FOS considers whether the financial business is required to provide financial compensation for distress or inconvenience it has caused. This consideration is made irrespective of whether specifically requested to by the complainant.

Where the degree of distress, inconvenience or other non-financial loss is sufficient to warrant compensation, the amount is generally likely to be modest. In only a small number of exceptional circumstances does compensation exceed £1000, with the majority being less than £300.

Example of modest compensation (less than £300)

Miss Y made a claim under her car insurance policy after she was involved in a road traffic accident. Her policy said that the insurer would provide alternative transport while her car was being repaired. However, she had to wait more than a week before the insurer arranged a hire car for her. During that time, she had considerable difficulties getting to work, as she lived in a rural area with poor public transport, The insurer eventually reimbursed her bus and taxi fares for the time when she was without a car, but she had still suffered inconvenience.

Example of a significant compensation award (£300-£999)

The business that provided Mrs C’s personal pension contacted her some six months after she retired. It said it had miscalculated her pension and had been underpaying her from the outset. The period concerned included one of the coldest winters on record. Mrs C had struggled financially to keep warm, but could have easily afforded her winter fuel bills if she had been receiving the correct pension.

Example of an exceptional compensation award (£1,000 or more)

Ms J obtained a loan with a credit provider so she could pay for a plumbing course. She contacted the provider a few months later, as she was unable to keep up with the repayments. The credit provider agreed to accept reduced repayments. However, it failed to note this on its records. Even though Ms J kept to the new arrangement, the credit provider started writing to her about her failure to keep to the initial agreement.

The credit provider knew that she suffered from serious mental health difficulties which were aggravated by stress. She explained this again – and reminded the credit provider that it had agreed new repayment terms. Despite this, she continued to receive numerous phone calls and letters demanding repayment – and she subsequently suffered a severe deterioration in her mental health.

Ombudsman Annual Review

The Financial Ombudsman Service (FOS) has published its annual review, covering the financial year 2010/11.

The review shows that during the year:

  • The ombudsman handled over a million front-line enquiries and complaints from consumers – around 4,000 each working day
  • Around 1 in 5 of the initial consumer enquiries received turned into a formal dispute requiring the involvement of FOS adjudicators – a record 206,121 new cases, up 26 on the previous year
  • 51% of the new cases were about the sale of payment protection insurance with the number more than doubling to 104,597 – the highest number ever received in a year about a single financial product.
Statistics from the ombudsman’s annual review show:


  • The number of investment complaints dropped by 30% and banking complaints fell by 9%
  • The ombudsman resolved almost half of all disputes (apart from PPI) in three months and three quarters within six months
  • The ombudsman’s involvement resulted in compensation for consumers in 51% of cases
  • Half of all disputes referred to FOS involved four of the largest UK financial services groups.

Talking about the report, the CEO and Chief Ombudsman Natalie Ceeney said: “This year has been the busiest in our ten-year history – with over 200,000 disputes referred to us and a million front-line enquiries. This reflects the increased confidence of an ever more diverse range of consumers getting in touch about a wider range of problems and issues.

Aside from PPI cases, over the year we’ve seen encouraging signs of improvements in the way that some businesses are handling complaints – and it’s good to see that the number of disputes about some other financial products has now started to fall.


Good Practice

Data Security

Customer data is any personal information held in any format, and it must be protected. Examples of customer data include:

  • National insurance records;
  • Addresses;
  • Dates of Birth;
  • Family circumstances;
  • Bank details; and
  • Medical records.
Information must be kept secure because of the potential for criminals to use the data (for reasons such as identity theft).

Customer data can be compromised in a number of ways and is not limited to data stored electronically. The physical safety of the business and supervision of visitors should be considered as much as having effective electronic protection.

Another risk concerns the vetting of new staff. In the past, the FSA noticed that when firms employ administrative staff only a basic reference check is requested. This is imprudent given administrators often have access to the majority of customer data.

The FSA advises firms to take a risk-based approach to reducing financial crime and encourages an enhancement on recruitment checks where appropriate.

Many firms employ third-party suppliers to carry out IT support or office cleaning and security. In these instances, people from outside your firm can have access to customer data.

Due diligence should be carried out on third-party suppliers before hiring them. Efforts should be made to ensure that these people have a good understanding of your firm’s security arrangements.

Having good data security policies and appropriate systems and controls in place will go a long way to ensuring customer data is kept safe. However, you need to ensure that staff understand the policies and procedures and your firm keep up-to-date with staff moves.

The FSA website contains examples of good and poor practice for financial crime and data security http://www.fsa.gov.uk/smallfirms/good_practice/protecting_your_business/financial_crimes.shtml

A self assessment tool is also available on the FSA website which allows firm’s to assess their current data security policy: http://www.fsa.gov.uk/smallfirms/resources/factsheets/pdfs/data_security.pdf

Impersonation of authorised firms

The FSA has noticed a significant rise in the number of overseas fraudsters using the names, addresses and registration numbers of authorised firms to try and convince consumers of their legitimacy.

These fraudsters, who use cloned versions of genuine firms’ websites, other publications and names of actual approved persons, are committing an offence. If you become aware of any such instances, you should inform the FSA.

You can add the address of your genuine website to the FSA register by amending your standing data using the ONA system.

 

CPD Summary

Our aim is to provide you with important regulatory information, keep you up to date with Industry news and provide you with new ideas for you to best service your clients and generate income. By reading our Newsletter every month you can collate your necessary CPD hours.