Training and Competence
The FSA requires all staff carrying our regulated activities to be competent to perform their role. Regulation has changed from what was originally a highly prescriptive set of rules, to a more principles based strategy. This is to enable companies to interpret and apply the principle of competence, as it applies to each individual businesses. This in itself can provide a dilemma for many companies.
So here are some general guidelines as to how many companies interpret the competence rule. You will appreciate that it is impossible to provide specific guidelines that will apply universally to all companies and the FSA focus is to allow an appropriate approach, for the size and nature of each firm. So you may be wise to seek expert advice, but these guidelines will act as a starting point.
- Staff should be assessed to identify the risk their role may have on future customer detriment
- Staff that are high risk should have their competence more closely monitored
- It is not sufficient to simply give staff training – they should be assessed in their competence as well
- New staff should be closely monitored by a competent person until assessed as competent
- Training and Assessments can take a number of formats. Very often e-learning is used, particularly for standardised subjects (such as Data Protection and FSA Regulation)
- Comprehensive record keeping is central to good T&C management
Staff Supervision is also given a very high priority:
- All employees must be supervised by an appropriate person at all times
- Staff monitoring may take the format of regular observation of them performing key elements of their role (such as CTI sales) using structured observational assessments
- The supervisor should have the necessary coaching and assessment skills and technical knowledge
Past experience has shown that the FSA treat the training and competence obligations of regulated firms very seriously and have imposed heavy fines on those firms who do not take the appropriate action to ensure the competence of their staff. The FSAare not disciminatory and have fined large PLC's as well as smaller organisations, so do not risk fine and censure for the sake of competent staff.
Note: Compliancy Services web based e-learning system provides standard e-learning and assessments for Regulated CTI firms, as well as formalised supervision via observational appraisals to make it easy for management to carry out all required Training, Competence and Supervision activity via one centralised system. Click here to contact us to find out more.
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