The FSA held a briefing on October 9th on wholesale brokers, although many of the topics discussed could equally apply across the spectrum of wholesale small firms.
What was particularly interesting was the summary given of themes that have emerged from a series of visits to around 300 small firms. Of most note was that documentation was frequently found to be out of date or even non-existent, and where it did exist in some cases “the ink was still wet on the compliance manual”.
We were promised more intrusive supervision going forward with more visits to small firms. Some themes to look forward to include; more scrutiny of group risk; more scrutiny of documentation and training; more work on capital adequacy; and more market/firm coordination to highlight best practice. Best put the kettle on now in anticipation of a visit.
We were reminded that the Wholesale Small Firms’ Strategy is “To improve the compliance of and increase the engagement with wholesale small firms”.
