PREPARING FOR A FIMBRA INSPECTION
| Date | 01 March 1994 |
| DOI | https://doi.org/10.1108/eb024812 |
| Pages | 234-238 |
| Published date | 01 March 1994 |
| Author | E. JOHN HAMP |
| Subject Matter | Accounting & finance |
PREPARING
FOR A FIMBRA INSPECTION
Received: 12th April, 1994
E.JOHN
HAMP
JOHN
HAMP
IS
A CHARTERED ACCOUNTANT AND IS
COMPLIANCE
MANAGER WITH COMPLIANCE
CONSULTANTS
LTD, PART OK THE
MACCLESFIELD-BASED
FINANCIAL SERVICES
TRAINING
(FST) GROUP. BEFORE
HE
JOINED
THE
FST GROUP HE WAS ONE OF UMBRA'S
TWENTY
OR SO REGIONAL COMPLIANCE
OFFICERS
WHERE FOR FOUR AND A HALF
YEARS,
HE WAS PRINCIPALLY INVOLVED IN
REGULATORY
VISITS THROUGHOUT THE
SOUTH
AND SOUTH WEST. PRIOR TO GOING
INDEPENDENT,
HE FILLED A VARIETY OF
ROLES
OVER 14 YEARS WITH ABBEY
LIFE
ASSURANCE
COMPANY IN BOURNEMOUTH,
INCLUDING
THOSE
OF INTERNAL AUDITOR
AND
COMPLIANCE OFFICER.
ABSTRACT
The
purpose
of
this
paper
is
to
give
readers
an
overview
of
a
routine
Financial
Inter-
mediaries,
Managers
and
Brokers
Regula-
tory Association (FIMBRA) compliance
visit and to
suggest
to new
members,
who
have
yet
to
experience
such
a
review,
a
basic
philosophy
that
might
make
the
pressures
of
regulation
easier to
accommodate.
Compliance
with FIMBRA's
rules
is
as
much
in
the
member's interests
as
it
is
in the
clients' since the
record-keeping
that is
insisted
upon
enables
advisers
to
show the
reasons
for their
recommendations
and to
prove how
thoroughly
they
have
explained
those
recommendations,
and any risks of
non-suitability,
to
those
clients.
The princi-
pal benefactors from
observing
FIMBRA's
rides
are
thus FIMBRA
members.
In the sense of last minute prepara-
tion implied by the title of this paper
a member cannot fully prepare for a
FIMBRA visit, or for any other regu-
latory visit for that matter. In all like-
lihood last minute preparation will
be a false exercise - a sort of window-
dressing.
When the author was a visit offi-
cer he came across day books and
client files which had been made neat
and tidy just for the visit. But the
only practical result of such concen-
trated effort was that a breach letter
that would have run to about eight
pages was reduced to just four. By
their industry the member had iden-
tified and remedied most of the
minor breaches but could not rem-
edy 'suitable advice' problems or
problems with the content of the
client files.
234
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