TABLE OF CONTENTS. Compliance Manual Version: 4.9 Author: [Your Company Name] Updated: 14/10/2017

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1 TABLE OF CONTENTS 1 Introduction Purpose & Scope of the Manual Responsibility for the Manual Regulatory Framework Introduction to the FCA Financial Services Regulatory Framework FCA's Objectives FCA Handbook Overview Compliance Program Introduction Scope of Your Business Regulatory Business Plan INSERT: Organisational Chart Status Disclosure Statement Compliance Statement Compliance Monitoring Document Compliance Officer Compliance Policy Principles for Business (PRIN) Introduction The Principles Our Approach to PRIN Conduct of Business (COBS) Introduction Conduct of Business Obligations (COBS 2) Conduct of Business Policy Client Agreements (COBS 8) Record Keeping for Client Agreements Providing Product Information to Clients (COBS 14) Senior Management Arrangements, Systems & Controls (SYSC) Introduction General Organisational Requirements INSERT: Business Continuity Compliance Compliance with the Rules Compliance Breach Policy Compliance Breach Procedures Breach Incident Form

2 6.6 Internal Audits Audit & Monitoring Policy & Procedures Compliance Monitoring Assessment Form Quality Assurance & Performance Policy & Procedures Appendix A - Staff Monitoring Form Risk Management Risk Management Policy & Procedures Risk Matrix Risk Register Risk Mitigating Action Plan Outsourcing General Requirements Introducer/Lead Generator Agreement Outsourcing & Supplier Policy & Procedures Record Keeping Guidance on Record Keeping Meeting Minutes Template Records Management Policy Records Retention Policy Records Retention Periods Register Change Management Policy Request for Change Form Conflicts of Interest Chinese Walls Conflicts of Interest Policy Conflict of Interest Register INSERT: Conflicts of Interest Procedures Whistleblowing Public Interest Disclosure Act Whistleblowing Policy & Procedures Whistleblowing Complaint Form (Template) Remuneration FCA Remuneration Code Principles Remuneration Policy INSERT: Remuneration Procedures Data Protection & Security Data Protection Commitment to Comply with Data Protection Act Data Protection Principles Data Protection Officer

3 7.2.1 Duties of the Data Protection Officer Designated Data Protection Officer Deputy Data Protection Officer Data Protection Policy & Procedures Data Protection Audit Privacy & Electronic Communications Regulations Employee Confidentiality Agreement Non-Disclosure Agreement (NDA) Template Information Security Information Security Policy Access Control & Password Policy BYOD & Remote Access Policy Asset Management Policy Information Asset Register (External) Secure Disposal Policy Clear Desk Policy Information Security Audit PCI Compliance PCI Compliance Policy Financial Crime & AML Introduction Proceeds of Crime Act Money Laundering Reporting Officer (MLRO) MLRO Annual Report National Crime Agency (NCA) The Financial Action Task Force (FATF) AML Measures & Controls Introduction Anti-Money Laundering Audit Anti-Money Laundering Policy & Procedures Suspicious Activity Reporting Suspicious Activity Report (SAR) Internal Template Bribery & Corruption Introduction Anti-Bribery Principles Anti-Corruption & Bribery Policy Know Your Customer & Due Diligence Introduction Know Your Customer Controls Enhanced Due Diligence

4 9.1.3 Politically Exposed Persons (PEPs) Cross-Border Due Diligence Non-UK Country AML Requirements Due Diligence Policy Due Diligence Questionnaire Due Diligence Checklist Market Abuse Introduction Market Abuse Policy Suspicious Transaction or Order Report (STOR) Form Insider List Template (Excel) Threshold Conditions (COND) Introduction Location of Offices Effective Supervision Appropriate Resources Suitability Business Model Threshold Conditions Policy & Controls Approved Persons & Controlled Functions (APER & FIT) Introduction The Statements of Principle for Approved Persons The Code of Practice for Approved Persons Approved Person & Controlled Functions Policy Controlled Functions Controlled Functions & Approved Persons Register SMF Roles SMF Manager Handover Policy Recruitment & Induction Introduction Competence Assessing & Maintaining Competence Supervisors Employee Recruitment Policy & Procedure Sample Interview Questions & Scoring Employee Induction Policy Induction Checklist Job Description Example Employee Training & Assessment Training

5 14.2 Training & Development Policy & Procedure Training Evaluation Form Training & Development Log Employee Training Record Employee Assessment Papers Assessment Structure Assessment Analysis Assessment Q&A Format Arrears & Default Assessment Q&A Papers (external) AML & Financial Crime Assessment Q&A Papers (external) DPA & Information Security Assessment Q&A Papers (external) FCA & Regulation Assessment Q&A Papers (external) TCF Assessment Q&A Papers (external) Vulnerable Customers Assessment Q&A Papers (external) Complaint Handling & Disputes Assessment Q&A Papers (external) Call Monitoring Checklist & Assessment Responsibilities to Customers Treating Customers Fairly (TCF) What is TCF? Expectations of Firms Six TCF Outcomes Treating Customers Fairly Policy Insert: Treating Customers Fairly Procedures TCF Procedure Guidance Treating Customers Fairly Audit Vulnerable Customers Approach to Vulnerable Customers Identifying Vulnerable Customers Debt & Mental Health MALG Debt & Mental Health Evidence Form (DMHEF) Vulnerable Customers Policy & Procedures Vulnerable Customer Audit General Provisions (GEN) Introduction Statutory Disclosure Status Additional Disclosure Requirements General Disclosure Notes Insurance against Penalties Consumer Call Charges Rules Appointed Representative (AR) Principal Requirements

6 Due Diligence for Appointing AR Appointed Representatives (SUP 12) Appointed Representative Monitoring Procedures Insert: Appointed Representative Agreement Insert: Appointed Representative On-boarding Procedures Supervision (SUP) Introduction General Guidance Reports by Skilled Persons Notifications to the FCA Reporting Requirements Internal Reports Management Information Policy FCA Reports Compliance Reporting Decision Procedure and Penalties (DEPP) Introduction Penalties Dispute Resolution: Complaints (DISP) Introduction Financial Ombudsman Service (FoS) Complaint Handling Complaint Handling Policy & Procedure Complaint Handling Log (Excel) Complaint Handling Form Complaint Handling & Disputes Audit Consumer Credit Sourcebook (CONC) Introduction Guidance on Financial Difficulties Financial Difficulties Policy Affordability Assessment Calculator (Excel) General Principles for Credit-Regulated Activities Credit Broking Credit References Credit Broker Refunds Transparency of Status Disclosure of Commission and Fees INSERT: Services and Costs Disclosure Document Lenders General Conduct

7 Provision of Credit Card Cheques Credit References Responsible Lending Policy Affordability & Creditworthiness Policy & Procedures Income & Expenditure Form Debt Counselling, Adjusting and Credit Information Services Distance Marketing Distance Marketing Policy Distance Marketing Checklist E-commerce E-Commerce Policy Financial Promotions & Customer Communication Communication & Financial Promotion Checklist Financial Promotions & Communication Policy Pre-Contractual Requirements Pre-Contract Disclosure Policy Key Features Disclosure Information Leaflet Pre-Contractual Checklist Commissions Continuous Payment Authorities CPA Policy & Procedures Post-Contractual Requirements Post-Contract Policy Cancellation & Refund Policy Arrears, Default & Recovery Introduction to Arrears Arrears & Default Policy & Procedures Arrears, Default & Financial Difficulty Audit Application of Interest & Charges Communication with Customers Data Accuracy Debt Recovery Policy & Procedures Debt Advice Credit Information Services Debt Management Plans Prudential Rules for Debt Management Firms Debt Advice Policy & Procedures Credit Reference Agencies Cost Cap for High-Cost Short-Term Credit Business Operational Procedures

8 21.1 INSERT: Add Own Procedures Here INSERT: Add Own Procedures Here Employee Declaration Compliance Declaration Form Compliance Audit Checklists......(External Pages) Employee Assessment Q&A Papers.....(External Pages) CASS Manual & Resolution Packs......(External Pages)

TABLE OF CONTENTS. Compliance Manual Version: 4.9 Author: [Your Company Name] Updated: 28/10/2017

TABLE OF CONTENTS. Compliance Manual Version: 4.9 Author: [Your Company Name] Updated: 28/10/2017 TABLE OF CONTENTS 1 Introduction... 10 1.1 Purpose & Scope of the Manual... 10 1.2 Responsibility for the Manual... 11 2 Regulatory Framework... 12 2.1 Introduction to the FCA... 12 2.2 Financial Services

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