dublin97

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Compliance Forum 18.5.05
Development in T C and the Impact on
SII Ruth Martin Managing Director
www.sii.org.uk
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FSA and FSSC

• Potential deregulation wholesale
• Potential changes in Controlled Functions
• Potential changes in Anti-Money Laundering
• Implications for Appropriate exams

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FSA

• Current review of T C Handbook
• Part of Business Plan for FSA
• Consultation Paper due end June 05
• Contain proposals to no longer require
  intermediaries to have appropriate examinations

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FSA (cont.)

• Appropriate examinations limited to retail
• Rationale linked to senior management
  responsibilities
• TC1 will continue to be required, but not TC2
• Rationale linked to FSA commitment to reduce
  burden for Firms

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Potential Changes to Controlled Functions

• Proposed to reduce and/or merge Controlled
  Functions
• Rationale linked to reducing burden and
  complexity

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Potential Changes to Anti-Money Laundering

• SII not involved in discussions to date have
  members of Compliance Forum been involved?

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Changing Dynamics FSA FSSC

• Appropriate list will no longer cover wholesale
  as MOU between FSA FSSC will include retail
  only.

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Changing Dynamics FSA FSSC

• FSA will be unable to enforce wholesale sector
  to use FSSC as FSSC role in wholesale limited to
  non-exam standards activities such as
  performance standards. FSSC likely to try and
  focus increasingly on these standards to try to
  keep a link.

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Changing Dynamics FSA FSSC

• Performance Standards need to be used as a guide
  in shaping new examinations and FSSC likely to
  try and make these more important. The proposed
  Compliance Standards and Anti-Money Laundering
  Standards fall into this category.

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Changing Dynamics FSA FSSC

• Major impact of FSA proposals on SII examinations
  if Firms no longer have to ensure staff pass
  examinations.

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Implications for Firms

• Initial discussions indicate that many Firms will
  welcome the changes and seek informal
  arrangements between Trade Bodies and SII to
  provide for examinations for the future.

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Implications for SII are

• Reduction in Certificates exam entries
• Careful review of retail definition, bearing
  Mifid in mind, as it relates to SII products
• More modular and bespoke exams for Firms in
  wholesale sector likely
• Impact on Compliance professionals?

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Next Steps

• SII Board will discuss developments tomorrow