Summary Page

Summary

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  • Overall Assessment

1) Firm

  • Business Update

  • Scope of regulated activities

  • Senior Managers & Certification Regime

  • Organisational Structure

  • Introducers & Sources of Business

  • Outsourcing

2) Sales Process & Management Information

Sales Process & Documentation

  • Sales Process

  • Sales Records

  • Sales Regulatory Disclosures

  • Sales Process Oversight

Management Information

  • MI Content and Adequacy

  • MI Review

3) Lenders, Remuneration and Incentives

Firm Lenders/Funders and Commissions

  • Lender/Funders

  • Fees and Commission Arrangements

Remuneration & Incentives

  • Remuneration/Incentive Scheme Review

4) Compliance Monitoring

Internal Compliance Monitoring, Reporting & Updates

  • Compliance Monitoring Plan

  • Breaches

  • Compliance Updates

  • Financial Crime

PPL Compliance Monitoring Activity

  • Sales File Checks

  • Audits/Inspections

  • Website Checks

  • Other monitoring activity

Website, Social Media & Financial Promotions

  • Financial Promotions Approval & Records

  • Website Review

  • Social Media

  • Other Advertising

5) Training & Competency

  • General Training

  • Compliance Training

  • Training Records

6) Complaints

  • Complaints Procedures & Handling

  • Complaints Records

  • Complaints Review

7) Testing

  • Sales File Checks:

  • Sales file details
  • Case Reference & Notes (including actions if applicable)

  • 2 CASES FOR REMOTE

Questions - 1) Firm

Business Update

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

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

  • Has the FS register been updated?

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

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

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

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?

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

  • Does the firm introduce customer to insurance?

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

  • 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?

Senior Managers & Certification Regime

  • Any changes to the SMFs?

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

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

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

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

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

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

Introducers

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

Outsourcing

  • Does the firm outsource any activities?

Questions - 2) Sales Process & Management Information

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?

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

Sales Records

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

Sales Regulatory Disclosures

  • Where does the firm disclose appropriate regulatory dislcosures

  • Are the regulatory disclosures correct?

Sales Process Oversight

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

  • Does the firm conduct internal sales monitoring?

  • Has the monitoring identified any remedial actions or training?

  • Does the firm record sales calls?

  • Is any monitoring of calls undertaken?

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.

Questions - 3) Lenders, Remuneration and Incentives

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?

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

Fees & Commission Arrangements

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

  • 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.

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

Remuneration & Incentives

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

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

  • 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?"

  • 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.?

Questions - 4) Compliance

Internal Compliance Monitoring, Reporting & Updates

Compliance Monitoring

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

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Regulatory Updates

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

Breaches

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

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

Financial Crime

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

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

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?

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

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

Website Checks

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

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

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

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?

Website, Social Media & Financial Promotions

Financial Promotions Approval & Records

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

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

  • Does the firm keep a record of financial promotions?

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

  • Are there any complaints arising out of Financial Promotions?

Website Review

  • Is the firms website compliant?

  • 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?

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

Other Advertising

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

Questions - 5) Training & Competency

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?

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))

  • (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 ?

Questions - 6) Complaints

Complaints Procedures and Handling

  • Are any published complaints procedures correct?

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

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

  • 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?

Complaints Records

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

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

Complaints Review

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

  • 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?

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

Complaint Cases

  • Complaint Case Review

  • Complaint case details
  • Case Reference & Notes (including actions if applicable)

  • There have been no regulated complaints to review.

Questions - General comments & Testing

  • General Comments

  • File check comments

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

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