I work for a small company of financial planners as their Compliance Manager. It is my job to ensure all activities of the business are carried out within the regulatory framework. In discharging my role I also need to ensure that my advice to the business takes account of the business objectives and that I demonstrate business acumen. In that I mean I provide solutions that are business friendly. At best this means that I can advise on potential opportunities to be gained through regulatory change and at worst I can advise the business not to undertake certain activities if it means the business would be exposed to a level of risk that would be difficult to manage
It is important that I understand the business so I get involved at all levels, including arranging and attending investment committee meetings and reporting to the Board on a regular basis. As we are a small company, I have regular dialogue with the firm’s Directors on compliance issues. My team know that they can come to me whenever they have a compliance issue and I will happily help, whether that is giving advice or reviewing their work.
I think it is important to note that I don’t know everything there is to know about compliance, after all views and opinions on what is good practice are evolving every day, but I do know where to find the information I need and I have external support that I can call on for a second opinion.
Much of my time is spent monitoring the controls I have put in place to mitigate compliance risk, so for example today I have been collating the firms MI for the quarter. I will use this information to identify any trends or new risks to the business and advise the Board on whether we need to take any remedial action. Remedial action can come in the form of amendments to policy and procedures and/or training and development of the firm’s employees. As well as this, I am running compliance projects to meet FCA requirements and preparing for an upcoming compliance audit that is undertaken by an external compliance consultant.
I must also ensure that I keep abreast of regulatory developments; after all, this moulds the way we do business. Keeping a track of what the regulator is saying is a good start, so I read speeches and corporate documents like the Retail Conduct Risk Outlook and the Business Plan so I can predict what actions we may need to take in future. Enforcement actions on other similar firms are also useful in showing how not to do things. Not only does this keep us compliant but hopefully future proof to changes, and most importantly sustainable.
One thing I have learned in my time working in compliance is that it is very easy to get bogged down in detail. Doing the ICA Diploma in Compliance helped take me ‘out of the box’ and really understand the universe I worked in and what my core responsibilities were. I mean, nobody told me when I started that I was a risk manager although that’s what I had been doing. It also helped me to think more strategically and now I manage my time more effectively because I address the business strategy and objectives first and foremost.
Morven Grierson is the Compliance Manager for S4 Financial Ltd.