A recent update on the SRA’s “Question of Ethics” page got us thinking about knock-on consequences for Compliance Officers.
By way of background, on 1 April 2013 the FSA will be abolished and split into three new regulatory bodies (the FCA, PRA and FPC).
Firms carrying out insurance mediation activities are considered “exempt professional firms” and must be on the EPF register, and also comply with the rules contained in the relevant sections of the SRA Handbook. (You send out those demands and needs statements for when placing title defect insurance and ATE, right?)
The SRA guidance specifically makes reference to the wording required by Rule 3.3 of the Financial Services (Conduct of Business) Rules 2001, which probably appears in your terms of business or other client information. This will require an update in April 2013 when the FSA is abolished. If you make reference to the FSA on your website, that too will need to be updated and any stocks of letterhead stationery may also need to be run down.
Why is this a COLP duty? By virtue of the SRA Authorisation Rules, the COLP must take reasonable steps to ensure that regulatory obligations are complied with.
