SFC compliance and licensing hints – Mar 2017

Responding to SFC surveys

The SFC conducts industry surveys and questionnaires every now and then. Whilst the SFC does have very wide powers to compel information, many of these survey requests are not mandatory. However, we typically recommend that clients participate anyway. Do you need to have your legal department or Deacons analyse each of the questions for you? Probably not. We suggest clients simply answer the questions as best as they can and keep a record of the basis of selecting / inputting a particular answer / number to ensure a consistent approach is taken to future questions, as these surveys often form part of a long-term information gathering exercise. If some of the questions are ambiguous, you can inform the SFC how you have interpreted the question. The SFC will seek clarification if it has any questions about your response.

CPT

The first quarter of 2017 is going to end shortly. It is time to remind all licensed individuals to plan ahead for meeting their 2017 CPT requirements in order to avoid a year-end rush.

Don’t forget that internal training can also be counted for these purposes provided it meets the SFC’s requirements as set out in the Guidelines on Continuous Professional Training. With changes in regulatory requirements (e.g. new client agreement requirements), new FAQs published by the SFC (e.g. compliance with suitability obligations) and the SFC inspection focuses (e.g. AML, Cybersecurity), firms should use CPT as the opportunity to make sure all of its licensed individuals are aware of the firm’s internal policies on these hot topic areas.