4 ‘To Dos’ for UK Financial Services firms

As we start the new year afresh, we thought it would be helpful to share four of the most common things that firms might forget that can lead to problems later!

1. Dates of regulatory returns due – Check RegData periodically (at least monthly) to see when items need to be submitted by. Some returns require significant time to prepare (e.g., MIF007) and you do not want be late submitting!

2. Risk and compliance policies annual reviews – Generally, most policies should be reviewed at least annually to ensure they are current still appropriate for the business of the firm, however forgetting to do this when you say you will review annually is not best practice. This can also be an issue where you have multiple policies that all need reapproving in the same month. We suggest firms look at what policies are due review during the year and stagger the reviews (by theme or category) so that the Board and committees have the capacity to consider the changes.

3. Risk Register – Often forgotten and very rarely fully refreshed. It’s helpful to have all business areas either quarterly or semi-annually confirm that the lists of risks and controls are complete and if there have been any incidents that should be reviewed to see if they create new risks that need to be added. This avoids the Risk Register becoming out of date and leading to large swings in add-ons for items like ICARAs and the quarterly regulatory returns.

4. Disclosures – This is the first year most firms will be making an external disclosure under MIFIDPRU. Don’t leave it too late as it needs to be made available on your website at a similar time to your annual accounts being published. Some firms may have done Pillar 3 disclosures, which is a good starting point, but firms should give themselves sufficient time as the new disclosures are different and do require information on risk and remuneration.

Also, consider signing up for the Objectivus Regulatory Updates, you won’t get in trouble for not doing this but you may find these quick updates and bulletins helpful in avoiding missing anything that might be relevant to your business.

If you would like to discuss any of the items mentioned or have questions for our risk, compliance and governance specialists please do get in touch.