Preparing for an FSA visit
It is a simple fact of life that your job can make you a hero or a social pariah. When was the last time you heard a Tax Man get a cheer from a game show audience? By the same token, when did you last hear a nurse get a boo from said audience?
Not even the FSA themselves would try and kid anyone that they are thought of warmly by those that they regulate, but what about the all important distinctions between the collective personality of a large institution and the people that work for it? Don’t lose sight of the fact that the people coming to see you are not genetically engineered automatons, but people with a job to do who would sooner work with you than against you.
Friday 25th November 2011 was a significant day for PSG SIPP Limited. A year after becoming authorised and regulated by the FSA, we had a visit from their CASS Unit. How did we do? In truth we can’t yet know for sure, but let’s just say they left with smiles on their faces that weren’t just to do with it being the end of a hard week for them, or the lunch we provided. We were pretty happy bunnies too.
We’ve all heard the adage ‘if you fail to plan, you plan to fail’ and whilst that slightly smug sounding nugget of wisdom is (hopefully) used with a certain sense of irony these days, it still rings true.
Regardless of whether you are a Provider, or an Adviser, or both, when you receive your notification from the FSA that they would like to pop over for a chat, how you react right there and then will go a long way to determining the outcome of the visit itself.
It’s no good running around like headless chickens and it certainly isn’t an option to just sit there assuming everything is already in place and wait for the door bell to go.
We immediately formed a small Project Committee to identify:
• how long we had to prepare;
• what our priorities were in this timeframe;
• who was going to do what;
• how it was all going to be monitored.
We were heartened by the fact that much of what the CASS unit were likely to be interested in was already well established as well as being more than adequate when measured against their criteria. However, what we chose to do was to think about how we would prepare for a full and intrusive FSA audit.
This involved us going back to all of our processes and procedures to review them and satisfy ourselves that they were fit for purpose, particularly with regards to Treating Customers Fairly and Handling Client Money.
We also reviewed our Systems and Controls, our MI, our staff training policy, our Auditing and Monitoring, our Whistle Blowing policy, our staff appraisal systems etc, etc. You get the idea.
You see, it’s not just about having all of these things and more besides in place and knowing that you designed them to work for your firm and for the FSA. It’s about reconnecting with all of these things to be certain they are up to date and to regain that familiarity with them so that everyone that should, can talk about them in detail, with confidence and without a script to follow.
In addition, we prepared a short presentation that we hoped the CASS Unit would allow us to use to give the day a start point. We knew they’d have certain questions as starters for ten, why not help them by pre-empting some of these and proactively provide answers? As well as making life easier for all, it demonstrates how seriously you take their visit, but also how confident you are in your understanding of what is required of you and your ability and inclination to deliver it.
One final but very important point to note though; this is not like preparing for an exam which is something that an individual must do on their own. How your organisation performs on the day will be down to how well you prepared as a team. Without cooperation from all areas, not just ‘key staff’ your preparation will never be as good, your performance will be well under par and you will have lost that opportunity to build your team without the aid of a lake, a raft to construct and an expensive day out of the office.