How are you preparing for your firm’s SM&CR and conduct rules training?
What has happened?
The Conduct Rules (COCON) are a key part of the SM&CR and they set minimum standards of individual behaviour in firms. By applying the Conduct Rules to a broad range of staff, the FCA intends to improve individual accountability and awareness of personal conduct issues across firms.
The Conduct Rules apply to almost all employees who carry out financial services activities, or linked activities, in a firm. Some Conduct Rules apply to all employees, while others only apply to Senior Managers as defined by the SM&CR.
The date when the Conduct Rules come into force for solo-regulated firms’ staff not classified as Senior Managers or Certified Persons is undergoing an FCA consultation at present and is expected to be delayed until 31st March 2021. Training must be provided to all such staff by that date.
What do you need to do?
When will the FCA be producing further communications regarding its expectations? – it is understood that it will produce some good/poor practices guidance on the Conduct Rules very soon. It is critical that staff undergoing this training understand how the Rules apply to them and what kind of breaches they may commit, and it is unlikely that this can be achieved by putting people through a quick training course. The course will need to focus on the individual’s role and it therefore will need to be tailored. It will be best delivered interactively by management.
There has been much discussion in the industry around what a conduct rule breach could look like. At the moment, monitoring conduct may be more difficult while many staff are working from home and may well do so for a long time. Many firms may need to revisit the mandatory training that they require staff to undergo in areas such as social media and data privacy policies.
How can we help you?
If you’d like to know more about how we can help you with your SM&CR and conduct rules training, or any other aspect of FCA compliance, our expert team is here to help. Contact us today on 0207 436 0630 – or email info@thistleinitiatives.co.uk.