Change Request Form and Management Register | Conflict of Interest and Chinese Walls | Mortgage Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

Change Request Form

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 [We have included a template for this document in 02_Manual_Supporting_Docs.]

7.13.2 Change Management Register

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 [We have included a template for this document in 02_Manual_Supporting_Docs.]

7.14 Conflict of Interest

A conflict of interest can occur where a person or firm could have their motivations influenced or corrupted by having an invested, personal, financial or emotional interest in a situation or activity.

The company confirms that it complies with its obligations under the regulatory system and that we have the required procedures and controls in place to: –

• identify conflict of interest between us (including all staff or any people linked to us), and a client of the firm or between a client of the firm and another client
• have a record of any type of conflict which may arise due to the nature and services that our firms offer and that any conflicts identified are added to this list and disseminated immediately
• manage any conflict and aim to prevent them prior to them arising
• ensure that where a conflict of interest cannot be prevented, it is disclosed to the client/s prior to any agreements or advice being provided

The company has a robust and comprehensive conflicts of interest policy and procedures in place which are maintained and reviewed frequently in accordance with our internal audit procedures.

7.14.1 Chinese Walls

Chinese walls are also referred to as ‘Information Barriers’ and are designed to prevent the spread of confidential information within a firm, which in turn helps to mitigate against conflicts of interest by ensuring that information is only available to those who need operational access to it.

Chinese walls within the company have been created between departments to prevent the unnecessary flow of information which is not relevant or required by other departments or employees to perform their job roles or tasks.

In their handbook, the FCA defines a Chinese Wall as “that is, an arrangement that requires information held by a person in the course of carrying on one part of the business to be withheld from, or not to be used for, persons with or for whom it acts in the course of carrying on another part of its business.”