SYSTEMS AND CONTROLS PROCESS
SYSC 2 & 7 (Corporate Governance, Committees, Terms of Reference, Management Information and Training). COLL 6.10.2: Senior Manager Personal Responsibilities
1.Implementation of investment policies
2.Oversee the approval of investment strategies
3.Ensure effective compliance function
4.Ensure investment policy and strategies and risk management (UCITS V & AIFMD) properly implemented
5.Review adequacy of internal procedures for undertaking investment decisions
6.Review adequacy and implementation of risk management policy and implementation
Systems and Controls not only incorporate IT systems, but also procedures that staff should adhere to, with oversight by appropriate individuals and reporting to management. It is the framework that sets out how the business operates and how decisions are made.
Controls are there to manage in an effective and efficient manner, which is consistent with the scale, risks, complexity and importance of the work (or risk). Policies and procedures enable us to run the business efficiently whilst considering the customer at every stage of their relationship with you.
Key FCA SYSC focus
Clear Organisation Structure
Manage, Monitor and Report Risks
Systems and Controls must be appropriate for nature, scale and complexity of the business
Managing Conflicts of Interest
Compliance with AIFMD
Training and Competence
MiFID II Article 5 covers knowledge, skills and expertise of employees. Under the FCA, this area also comes under Training and Competence Sourcebook, in conjunction with the Systems and Control Sourcebook (SYSC):
A firm must employ personnel with the skills, knowledge and expertise necessary for the discharge of the responsibilities allocated to them (sysc 3.1.6). Covers training and competence.
All firms need to make sure that an employer has passed some sort of qualification and is competent to
advise and deal
act as a broker or fund adviser
advise on syndicate participation at Lloyds
act as a pension specialist
(Note under RDR – effective 1 Jan 2013 all financial advisers need to hold a level 4 qualification)
31st Dec 2012 all investment advisers should a Statement of Professional qualification and undertaken appropriate CPD training of 35 hours.
To demonstrate compliance with the rules in the Training and Competence Sourcebook.
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