File Reviews and Audits

TYPE OF FSP

  • CLIENT CORRESPONDENCE AND FILES AUDITED: PERIOD:

  • This FSP is licenced as a:

  • Only intermediary services, and no advice is provided

  • A documented, correct service level agreement is in place between:<br>1. Product supplier and FSP<br>2. Brokerage and FSP (where applicable)

  • It is incumbent on the FSP to ensure that there are adequate drafted service level agreements - as these are the basis on which service can be measured from a TCF perspective. Please ensure this is attended to a.s.a.p.

  • Administrative procedures are in place, to ensure proper process, checks and balances and controls. Deviations are noted and addressed

  • Notes:

  • Files Audited:
  • DATE OF AUDIT

  • Name of Client

  • Disclosures correct

  • Services provided within the agreed SLA

  • Correspondence clear, correct and complete

  • The product performs as it has been led to perform (TCF Pillar 5)

  • NOTES:

  • PHOTO EVIDENCE

  • Add media

  • FILE AUDITS

  • FILE AUDITS
  • DATE OF AUDIT

MOTOR DEALERSHIP

  • Name of Representative:

  • Transaction Date:

  • Name of client/file

  • A due diligence has been completed on products and product providers recommended

  • Date the representative last received product training on the recommended product

  • Offer to Purchase - on file and correct and complete

  • Invoice - figures on invoice are the same as the OTP

  • Full Product and Fees disclosures - evident

  • Contract - Page 1 on file

  • Record of advice - correct updated version

  • Record of advice - complete, initialled every page

  • Cash deal / Cash deposit

  • FICA verification done

  • It is critical that the correct FICA verification and documents are on file. Please ensure that staff are retrained on this, and that the matter is attended to as priority.

  • Reportable transaction

  • All FICA reporting done within the required timeframes: 1) Threshold transaction - 2 days 2) Suspicious/ Unusual - 5 days 3) Terrorist financing - 15 days

  • Non-reporting of FICA reportable matters within the required timeframes, places the dealership at risk. Please ensure this matter is addressed as a priority as this is a material non-compliance which carries severe penalties.

  • Insurances on file

  • Drivers licence - correct, up to date, valid

  • Correspondence on file/ File Notes/

  • Deal File compliant - all documents are complete, correct (including dates and signatures) - all transaction values match

  • Documents are correctly and comprehensively completed

  • Has a system been implemented which ensures regular product training. Describe.

  • Evidence of KI checking - monitoring

  • Notes/ Comments:

  • Files Audited for compliance

  • Files Audited

File Audits CAT I - SHORT TERM

  • DATE OF AUDIT

  • Name of Representative:

  • Date of Transaction:

  • Name of client/file

  • A due diligence has been completed on products and product providers recommended

  • Disclosure document - is this the correct, updated document

  • Consent to obtain information/ Schedule provided<br>

  • Is the transaction a comparison off an existing schedule only, a new quote completely, or a combination of schedule and advice/ assessing risk

  • Broker Appointment - on document/ application form or other

  • Full product and fees disclosures

  • Mandate/ Evidence of Instruction being provided by client

  • Information gathering in order for intermediary to perform analysis

  • Evidence of analysis

  • Quote signed and on record

  • Application form complete, with no blank areas (customer did not sign an incomplete form)

  • Claims History - (short term)

  • Record of advice - complete and copy provided to client.

  • RPAR - correct, complete, copy to client

  • Correspondence/ File notes/ Records of engagement

  • Documents are correctly and comprehensively completed 1-not at all 10- Perfect!

  • Evidence of KI checking/ assessing content, plus appropriateness

  • Has a system been implemented which ensures regular product training. Describe.

  • Notes/ Comments

  • Files Audited for compliance

  • Files Audited

File Audits CAT I

  • DATE OF AUDIT

  • Name of Representative:

  • Date of Transaction:

  • Name of client/file

  • A due has diligence been completed on products and product providers recommended

  • Consent to obtain information<br>

  • Disclosure document

  • Broker Appointment - on document/ application form or other

  • Mandate/ Evidence of Instruction being provided by client

  • Information gathering in order for intermediary to perform analysis

  • Evidence of analysis and risk assessment

  • Quote signed and on record

  • Application form complete, with no blank areas (customer did not sign an incomplete form)

  • FICA verification (verified ID/Proof of address/Source of funds) DATED?

  • FICA verification is signed and dated, and less than 2 years, with a process in place to re-verify at least once every 2 years:

  • Record of advice - complete and copy provided to client.

  • Full product features, risks and fees disclosures confirmed

  • RPAR - correct, complete, copy to client

  • Correspondence/ File notes/ Records of engagement

  • Documents are correctly and comprehensively completed 1-not at all 10- Perfect!

  • Evidence of KI checking/ assessing content, plus appropriateness

  • Has a system been implemented which ensures regular product training. Describe.

  • Has a system of feedback from customers been implemented to identify any problematic areas?

  • Notes/ Comments

File Audits - CAT II

  • Files Audited for compliance

  • Files Audited
  • DATE OF AUDIT

  • Date of transaction:

  • Name of client/file

  • Disclosure document is correct and includes Section 13 certification?

  • Consent to obtain information<br>

  • Intermediary appointment on file

  • CAT II mandate on file, complete and signed

  • CAT II mandate is confirmed as the approved version

  • Was advice provided?

  • Is there a record of advice on file, in compliance with the requirements of a CAT I provider?

  • Information gathering in order for intermediary to perform analysis

  • Evidence of analysis and risk assessment

  • Is there evidence of assessing the customer's risk profile or motivating why a certain risk approach is undertaken

  • FICA verification (verified ID/Proof of address/Source of funds)

  • FICA verification is signed and dated, and less than 2 years, with a process in place to re-verify at least once every 2 years:

  • Reporting is done at least quarterly, in accordance with the Mandate

  • Correspondence/ File notes/ Records of engagement

  • Documents are correctly and comprehensively completed 1-not at all 10- Perfect!

  • Product due diligence complete

  • Describe the process of ensuring that the Mandate is complied with. If there are any breaches, provide details on what these were as well as how they were addressed

  • Has a system of feedback from customers been implemented to identify any problematic areas?

  • Notes/ Comments

SIGNATURE:

  • COMPLIANCE

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