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Notifications to the FCA

The company is required to provide a wide range of information to the FCA so that they can meet their responsibilities in monitoring us for regulatory compliance. We confirm that we have systems and controls in place to provide all the necessary and required information within the timeframes set out by the regulator.

The company understands it obligations and duty to notify the FCA immediately should one or more of the below occur: –

  • the firm failing to satisfy one or more of the threshold conditions
  • any matter which could have a significant adverse impact on the firm’s reputation
  • any matter which could affect the firm’s ability to continue to provide adequate services to its customers and which could result in serious detriment to a customer of the firm
  • any matter in respect of the firm which could result in serious financial consequences to the UK financial system or to other firms

The company confirms that all its staff have been directed to deal with the FCA in an open, honest and cooperative manner and to disclose anything which relates to the firm of which the regulator would usually expect to be notified.

The company understands and is committed to its obligations of reporting any breach as covered in the FCA Handbook SUP 15.3.11, any instance of fraud of financial irregularity (SUP 15.3.17), any civil, criminal or disciplinary proceeding against the firm (SUP 15.3.15) or any instance of insolvency, bankruptcy or winding-up (SUP 15.3.21).

18.5 Reporting Requirements

The company confirms that it has procedures and controls in place to provide the FCA with the regulatory required information and reports and we understand that in doing do, all information must be presented in an accurate and timely manner and on a frequent and ongoing basis.

The method and delivery of all reports to our regulatory will comply with the requirements set out in SUP 16.3.8 – SUP 16.3.13 of the FCA Handbook.

18.5.1 Internal Reports

The company has robust records management and internal reporting procedures to ensure that frequent Management Information (MI) is provided to the Senior Managers and Directors on an ongoing basis. Such information is indicative of our business objectives and regulatory requirements and aids us in ensuring compliance.

18.6 Management Information Policy

1. Policy Statement

The company has robust Management Information (MI) and internal reporting procedures to ensure that frequent MI is provided to the Senior Managers and Directors on an ongoing basis. Such information is indicative of our business objectives and regulatory requirements and aids us in ensuring compliance, providing gap analysis and keeping those in AP and SMF roles apprised of our current progress and ongoing aims.

Our MI is gathered through audits, reviews, assessments, ongoing analysis and management feedback and enables the company to assess compliance, meet our objectives, analyse any gaps and meet our regulatory obligations. Such information is used to review and renew our procedures, activities, aims, training provisions and keep the management team updated and aligned with our objectives.

We aim with our MI to be active as oppose to reactive, working on future solutions and provisions oppose to fixing issues as and when they occur. This better enables effective risk management and assessment and also helps to prevent compliance breaches and impacts on customers.

Our management information comes from: –

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  • Account data analysis
  • Business objective analysis
  • Training and competence records
  • Staff assessments and feedback
  • File reviews
  • Customer feedback
  • Complaint reports
  • Compliance reports
  • Audit checklists and monitoring assessments
  • Due diligence data
  • Accounting reports and data
  • TCF audits and dashboard data
  • FCA reporting data

2. Purpose

The purpose of this policy is to outline the company’s objectives and obligations with regards to internal and external management information (MI). MI is an important and mandatory part of our business function and ensures that all staff with a role to play in keeping our business and services compliant, are aware of our progress, activities and intentions. MI provides valuable information to senior management, Directors and those performing Approved Persons and/or SMF roles within the company and better enables us to serve the interests of our customers whilst ensuring that we are and remain compliant with the regulatory system and our own business objectives.

The company is also dedicated to the TCF ethics and principles, of which MI plays and important role. Gathering the right MI enables us to see areas of good and poor practice with regards to customer treatment and service and provides necessary gap analysis data for procedures that need to be reviewed and updated. As TCF must be embedded into all areas of our business to work effectively, most MI reports will contain elements of the TCF principles, by which they will be measured.

3. Scope

The policy relates to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the company in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

4. FCA Reports

The company submits a wide range of MI and reports to the FCA as part of our regulatory obligations, however all such reports, except for compliance reports, are beyond the scope of this policy and staff are directed to refer to the FCA Handbook under section SUP 16 for further guidance and information.

Compliance Reporting

As part of its regulatory oversight functions, the FCA review and analyse information about the company’s records of compliance with the regulatory requirements, to ensure that we are meeting our obligations in each area.

The company keep records of all compliance audits and assessments that show our compliance with the regulatory, statutory and legal requirements placed upon us and that these records are kept and shared with our regulators, in an open, transparent and cooperative manner.

5. Management Information

The company collects, uses, reports on and retains all Management Information (MI) through our usual periods of business activity and daily tasks. Our MI provides us with valuable and necessary data with which to improve our business functions and customer service as well as reducing the risks to both areas.

MI is obtained from all areas of the business, from initial sales and on-boarding, through to our accounting procedures and complaint records. Rather than being just a set of numbers and data, MI provides useful and constructive information for our management, Directors and regulators.

To ensure that the company gets the most out of our MI, we ensure that it follows the FCA’s guidance for being: –

  • Accurate – the correct numbers with any commentary contributed by the right people.
  • Timely – available sufficiently quickly after the relevant business activity to enable managers to act.
  • Relevant – displaying what a manager can directly influence or something that they may need to escalate to someone who can take the necessary action.
  • Consistent – consistent on a period-to-period basis to allow managers to spot trends and make sound decisions.

In addition to our standards and documented MI, we also have areas of ‘instant’ MI whereby data and/or figures are requested for a specific function or activity. These are done on an ad-hoc basis and are for areas where there is a particular concern, new business activity areas or compliance areas that need to be monitored more frequently to avoid breaches and reduce risks.

For all instances of Management Information (MI) we follow the regulatory guidelines when collecting, using and recording the data to ensure that we are compliant, and it is effective: –

  • Seen – an appropriate level of management receives, understands and reviews the MI
  • Challenged – anomalous or unexpected results are challenged
  • Analysed and Monitored – the right messages and conclusions are drawn from the data
  • Acted On – where appropriate, actions are taken to remedy the situation, to investigate further and to follow up on those actions
  • Recorded – records are made of what is done and information is subsequently gathered to enable the success of those actions to be assessed.

6. Objectives

The company has laid out the below objectives and aims that ensure we comply with and adhere to all regulatory and legal requirements as well as meeting our own internal business obligations and aims. MI reports and schedules are recorded on a separate reporting document along with audit and monitoring schedules and data.

With regards to Management Information, the company ensures that: –

  • We operate a scheduled MI gathering system that is adhered to by all staff. MI reports are run at specific times and intervals to allow for the best data analysis to be conducted.
  • MI is analysed and reviewed by an appropriate person/s who has the knowledge and skill to interpret and report on the content effectively and sufficiently.
  • MI gathering is conducted at consistent intervals to allow any trends and patterns to be identified and sound decisions to be made.
  • All MI reported on is compliant with regulatory and legal requirements and meets the expected standards of the FCA.
  • MI adequately covers the needs and functions of the business and ensures that all areas are assessed and reviewed on a continual basis.
  • Staff are part of the MI reporting structure, including their training, competency, understanding and adherence to compliance.
  • TCF forms an integral part of all MI and allows for the assessment of the principles within each business area.
  • MI is gathered in a timely manner; ensuring that all data is up-to-date and relevant when reviewed and reported on.
  • MI reports are always acted upon and the data used to improve business decisions and procedures.
  • MI measures our performance as well as helping us to identify potential risks before they happen.
  • Appropriate and relevant MI data is shared with all staff to ensure a complete understanding of their firm’s progress, current standing, objectives and any areas for improvement.
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7. Responsibilities

The company ensures that all staff are provided with the time, training and support to learn, understand and help to the objectives in this Management Information Policy, so as to comply with our own internal aims and obligations and to meet and continue to achieve the legal and regulatory requirements.

Senior Management and those holding Approved Persons and Senior Management Function roles are responsible for ensuring that this policy and its agenda is complied with and enforced throughout the organisation.

18.6.1 FCA Reports

The company submits a wide range of information and reports to the FCA as part of our regulatory obligations, however all such reports, except for compliance reports, are beyond the scope of this manual and staff should refer to the FCA Handbook under section SUP 16 for further guidance and information.

18.6.2 Compliance Reporting

As part of its regulatory oversight functions, the FCA review and analyse information about the company’s records of compliance with the regulatory requirements, to ensure that we are meeting our obligations in each area.

The company confirms that we keep records of all compliance audits and assessments which show our compliance with the regulatory, statutory and legal requirements placed upon us and that these records are kept and shared with our regulators, in an open, transparent and cooperative manner.