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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

  • Corporate Governance

  • Clear Organisation Structure

  • Reporting Lines

  • Manage, Monitor and Report Risks

  • Business Continuity

  • Accounting Policies

  • 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)


Maintaining Competence

31st Dec 2012 all investment advisers should a Statement of Professional qualification and undertaken appropriate CPD training of 35 hours. 


Record Keeping

To demonstrate compliance with the rules in the Training and Competence Sourcebook.

For further information please click on the members tab at the top Systems and Controls. 

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