DA Interim Assessment

• Site conducted

  Select

• Date:

  Date

• Location:

• Firm's Nominated Contact(s):

• Conducted By:

Summary

• undefined

• Overall Assessment

  Select Rulebreach or significant concerns raised Less than satisfactory Improvement Required No Issues Identified

  • Rulebreach or significant concerns raised
  • Less than satisfactory
  • Improvement Required
  • No Issues Identified

• Business Update

  Amber

  Red

  Yellow

  Green

• Scope of regulated activities

  Amber

  Red

  Yellow

  Green

• Senior Managers & Certification Regime

  Amber

  Red

  Yellow

  Green

• Organisational Structure

  Amber

  Red

  Yellow

  Green

• Introducers & Sources of Business

  Amber

  Red

  Yellow

  Green

• Outsourcing

  Amber

  Red

  Yellow

  Green

Sales Process & Documentation

• Sales Process

  Amber

  Red

  Yellow

  Green

• Sales Records

  Amber

  Red

  Yellow

  Green

• Sales Regulatory Disclosures

  Amber

  Red

  Yellow

  Green

• Sales Process Oversight

  Amber

  Red

  Yellow

  Green

Management Information

• MI Content and Adequacy

  Amber

  Red

  Yellow

  Green

• MI Review

  Amber

  Red

  Yellow

  Green

Firm Lenders/Funders and Commissions

• Lender/Funders

  Yellow

  Red

  Amber

  Green

• Fees and Commission Arrangements

  Yellow

  Red

  Amber

  Green

Remuneration & Incentives

• Remuneration/Incentive Scheme Review

  Yellow

  Red

  Amber

  Green

Internal Compliance Monitoring, Reporting & Updates

• Compliance Monitoring Plan

  Red

  Amber

  Yellow

  Green

• Breaches

  Red

  Amber

  Yellow

  Green

• Compliance Updates

  Red

  Amber

  Yellow

  Green

• Financial Crime

  Red

  Amber

  Yellow

  Green

PPL Compliance Monitoring Activity

• Sales File Checks

  Red

  Amber

  Yellow

  Green

• Audits/Inspections

  Red

  Amber

  Yellow

  Green

• Website Checks

  Red

  Amber

  Yellow

  Green

• Other monitoring activity

  Red

  Amber

  Yellow

  Green

Website, Social Media & Financial Promotions

• Financial Promotions Approval & Records

  Red

  Amber

  Yellow

  Green

• Website Review

  Red

  Amber

  Yellow

  Green

• Social Media

  Red

  Amber

  Yellow

  Green

• Other Advertising

  Red

  Amber

  Yellow

  Green

• General Training

  Yellow

  Red

  Amber

  Green

• Compliance Training

  Yellow

  Red

  Amber

  Green

• Training Records

  Yellow

  Red

  Amber

  Green

• Complaints Procedures & Handling

  Yellow

  Red

  Amber

  Green

• Complaints Records

  Yellow

  Red

  Amber

  Green

• Complaints Review

  Yellow

  Red

  Amber

  Green

• Sales File Checks:

  Compliant

  Non-Compliant

  N/A

  Minor Issue/Concern
Sales file details

• Case Reference & Notes (including actions if applicable)

• 2 CASES FOR REMOTE

Business Update

• Review of Companies House - Are there any changes that need action?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Is the firm using any new Trading names/styles?

  Yes

  No

  N/A

  Minor Error/Issue Identified

  Unable to Assess

• Has the FS register been updated?

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

• Have there been any other changes to ownership, shareholders, controllers or directors, that PPL/the FCA need to be aware of?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Has the FCA been notified of the changes (if applicable?)

  Yes

  No

  N/A

  Minor error/issue identified

• Has the business activity, customer market or the range of products sold changed since the last review, or are there any plans to change?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Scope of regulated activities

• What is the firms main line of business, e.g car dealer, online bikes, online and retail store bed sales, etc

• What is the main business activity of the company?

• Description of firms activities required i.e. Credit Broking, Secondary broking, debt counselling, debt adjusting, insurance mediation etc. as advised by AR

• List the firm's FCA Permissions

• E.g. Offering goods they own on finance to the customer ( consumers ), mainly PCP and HP

• What regulated activities does the firm undertake?

• Have these activities changed since the last review?

  Yes

  No

  N/A

  Minor Error/Issue Identified

  Unable to Assess

• Insurance - Any evidence on FS register or Website if not on FS register

• Does the firm introduce customer to insurance?

  Yes

  No

  N/A

  Minor Error/Issue Identified

  Unable to Assess

• If yes, do they have the necessary permissions or RAO exemptions?

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

• Check that the firm is not selling any products or services that are outside of the their permissions.

• Does the firm have the necessary permissions for their regulated activities?

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

Senior Managers & Certification Regime

• Any changes to the SMFs?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Any new legal directors that should be Directory Persons (if not needing to be SMFs?)

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Is the FCA Senior Manager/FCA Approved Person still involved in the business?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Do Company details and SMF details match PPL/ FCA records?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Does the firm have any new staff that are Certification Level that have not been added to the FS Directory?

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

Organisational Structure

• Number of Employees in the firm.

• Does the firm have an up to date organisational chart in place/or other document confirming reporting lines etc

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Does the firm have sufficient staffing resources for the oversight of regulated activities?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Introducers

• Does the firm use any Introducers, brokers, agents or other sources of business?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Outsourcing

• Does the firm outsource any activities?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Sales Process & Documentation

Sales Process

• Check that the firm has a documented sales process in place; Establish how customers receive sufficient information in order to make an informed decision. i.,e the customers are provided an IDD Information Notice, and the firm's Terms and Conditions, formal quotation, finance proposal form and a formal order form.

• Have there been any changes to the sales process since the last assessment/audit?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Does the documentation/information provided to the customer during the sales process contain sufficient information for the customer to make an informed decision?

  Yes

  No

  N/A

  Minor error/issue identified

Sales Records

• Establish that the firm has adequate sales records in place, either via CRM/system or paper files.

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Sales Regulatory Disclosures

• Where does the firm disclose appropriate regulatory dislcosures

• Are the regulatory disclosures correct?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Sales Process Oversight

• Review how sales advisers are monitored; Review internal monitoring;

• Does the firm conduct internal sales monitoring?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Has the monitoring identified any remedial actions or training?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Does the firm record sales calls?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Is any monitoring of calls undertaken?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Management Information

MI Content and Adequacy

• Review whether the firm is collecting MI and if so whether this is sufficient to ensure that the firm is compliant and that customers are receiving a fair outcome; Review levels of oversight of MI output to ensure appropriate level of scrutiny.

• Does the firm produce sufficient Management Information ensure that the firm is aware of the regulatory risks? Including detailing the frequency and source and whether this is deemed adequate for the nature and scale of the firm.

Firm Lenders/Providers and Commissions

Lenders /Providers

• Which Lenders/Providers does the firm currently use?

• Has the firm started using any new Lenders/Providers since the last review?

  Yes

  No

  N/A

  Minor Error/Issue Identified

  Unable to Assess

• Has the firm demonstrated that they have conducted sufficient due diligence on the Lender/provider to ensure a suitable fit for their customer base?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Fees & Commission Arrangements

• Does the firm charge customers a Fee? (separate from any commission/remuneration earned)

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Ensure that where a firm charges customers a fee, this is correctly detailed in the Information Notice that is issued and this is signed by the customers.

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Check that the existence of Commission is 'prominently' disclosed to customers and that the wording of the commission disclosure is correct.

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Remuneration & Incentives

• Any changes to the firms remuneration scheme/incentive scheme since the last assessment?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Has the firm provided a copy of its remuneration /bonus scheme details?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• What percentage of overall salary can be earned as bonus? (if applicable)

• Do the sales staff have any KPI's. i.e. sales target (£ or volume) or customer service scores, low complaints etc?"

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Under what circumstances would bonus be deducted from staff involved in regulated activity?

• Documentation Review - Does the firm’s remuneration scheme take account of compliance & quality measures?

• Documentation Review - Assess whether the remuneration scheme in place has the potential to drive behaviours that could cause potential customer detriment.

• For example are there any events or checks in place that could result in a deduction or pay, commission or bonus?

• Are there any conflicts arising due to the incentives for individuals who directly supervise sales staff involved in the sale of finance products or for individuals who may play a key role in identifying mis-selling and at the same time receive incentives to maximise sales.?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Internal Compliance Monitoring, Reporting & Updates

Compliance Monitoring

• Is the compliance monitoring plan correct and being used? (Review Plan)

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

• undefined

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Regulatory Updates

• Are relevant staff kept up to date with policies and regulatory updates

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

Breaches

• Have there been any compliance or Data Protection breaches since the last review?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Have these been recorded on the breaches register and appropriate authorities notified (if applicable)?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Financial Crime

• Have there been any confirmed or suspected instances of financial Crime?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Have these been recorded on the Financial Crime register and the appropriate authorities notified (if applicable)?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

PPL Compliance Monitoring Activity

Sales File Checks

• Any concerns, trends or issues identified from PPL monitoring activity - File Checks

• Detail how many file checks have been completed and the average score. Detail the lowest score

Audits/Inspections

• When was the last assessment/audit?

  Date

• Have all the actions from the previous audits/assessments been completed?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Has the firm & PPL agreed a timeframe to close any outstanding actions?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Website Checks

• How many webchecks have been completed since the last assessment/audit?

• Have all the actions from the previous webchecks been completed?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Has the firm & PPL agreed a timeframe to close any outstanding actions?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Other monitoring activity

• What other monitoring activity has been conducted for the firm?

• Any concerns, trends or issues identified from PPL monitoring activity - other activity?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Website, Social Media & Financial Promotions

Financial Promotions Approval & Records

• Any changes to the documented internal approval process for Financial Promotions?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Does the firm send financial promotions to PPL for approval prior to use?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Does the firm keep a record of financial promotions?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Any evidence of non-approved or out of date financial promotions? (Either on the register or found elsewhere?)

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

• Are there any complaints arising out of Financial Promotions?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

Website Review

• Is the firms website compliant?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Detail areas of non-compliance requiring rectification.

• Detail areas of non-compliance requiring rectification.

Social Media

• PA: Is there any evidence of finance being advertised on social media?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Are the posts on social media compliant where finance advertised?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Other Advertising

• Have any concerns been raised regarding any of the firms general advertising?

  Yes

  No

  N/A

  Minor error/issue

  Unable to assess

General Training

• What general training has been undertaken on firm procedures and products etc?

Compliance Training

• Check PPL training records to establish if employees have completed relevant compliance training - complaints, conduct rules, financial crime, data protection, etc - If the firm does their own training, require sight of training completed

• Have all relevant staff within the firm completed appropriate compliance/regulatory training?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Training Records

• Check if firm has training records in place which detail the training undertaken by the employees?

• Training register and individual training logs provided? (NOTE Are these adequate evidence of training? (up to date, relevant content etc))

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• (Firm hasnt provided training logs so ask) "What training records does the firm maintain?"

• Does the firm have adequate records of all training undertaken by each member of staff ?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Complaints Procedures and Handling

• Are any published complaints procedures correct?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Any changes to the person with overall responsibility for Complaints Handling within the firm?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Have individuals tasked with dealing with complaints had adequate training?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Complaints Contact Information - Note down the complaints contact information (FS Register, documents and websites) - any differences?

• Are the complaint contact details on the website and on the FS Register correct?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Complaints Records

• Does the firm have a record of FCA reportable complaints received?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

• Is this up to date and does it contain sufficient level of detail?

  Select Yes No N/A Minor Errors/Issues Identified Not required Unable to assess

  • Yes
  • No
  • N/A
  • Minor Errors/Issues Identified
  • Not required
  • Unable to assess

Complaints Review

• Are there any trends or concerns relating to NON-FCA reportable complaints that the firm needs to take action on?

  Yes

  No

  N/A

  Unable to Assess

  Minor Error/Issue Identified

• Any trends relating to reportable complaints that are cause for concern or require action to be taken?

• Are there any poor internet reviews which could be classed as complaints?

  Yes

  No

  N/A

• Have these reviews been responded to in line with the firm's complaint procedures?

  Yes

  No

  N/A

  Minor error/issue identified

Complaint Cases

• Complaint Case Review

Complaint case details

• Case Reference & Notes (including actions if applicable)

• There have been no regulated complaints to review.

• General Comments

• File check comments

• ***********JUST EXIT IF REPORT NOT FULLY COMPLETED ******************