Looking ahead to next year’s first big date for financial services professionals: January 3, 2018

Is the pressure starting to build in your firm? With MiFID II, GDPR, SMCR, IDD, and PRIIPs regulations coming in to play in 2018, the race to be compliant is definitely on. Two key dates are high on the agenda: January 3 for MiFID II and May 25 for GDPR, while the lack of a confirmed date for the extension of SMCR isn’t going to be helping with forward planning too much.

With so much change ahead, it’s important to think about  what connects it all and what your firm needs to do to ensure it is fit for purpose come January 2018 and beyond.

The ‘connector’ for all this incoming regulation is Training & Competence (T&C). T & C – ensures your people are competent to successfully do the job, in terms of regulatory requirements, they’re employed to do.

Whenever there are significant regulatory changes, especially like those set for 2018, it’s the policies, procedures, systems and controls you have in place which you need to scrutinise, as well as fill in the gaps. Furthermore, it’s crucial to ensure you have the supporting evidence to show your firm, and the people employed to run and govern it, are fit and proper to do just that.

Defining Fit & Proper

It’s important to remember fit and proper is not just a simple matter of carrying out a credit check to ascertain whether someone is financially sound or not, or a DBS to check they haven’t committed a crime. Fit and proper pertains to the competence of those individuals to undertake their job role.


Training & Compliance, MiFID II, GDPR, SMCR, IDD, PRIIPS


The business landscape is always evolving, and at greater speed in 2018 with the wave of regulation, therefore an effective T&C scheme should always be evolving to keep your staff members and the business efficient.

You may want to ask yourself a few questions about what you already have in place; see the table below for starters.

If you feel you’re missing any of these elements or want further peace of mind around them speak to us today. We’re helping firms like yours ensure they have demonstrable and effective policies and procedures aligned to the most up to date criteria and there are numerous benefits too – peace of mind being just one of them!

Is your T & C scheme fit for purpose to meet the new requirements of the relevant changes applicable to your firm? Guarantee your T&C scheme is fit for purpose and aligned to meet the relevant changes facing your firm.
Is our Recruitment Policy aligned to the requirements? Assurance your recruitment policy and processes meet the requirements.
Are the competencies all our relevant people should be assessed against in place? Have the right knowledge to assess all relevant staff against the most up to date competencies.
Is there a Succession Programme? Develop an effective Succession Programme that results in home grown talent with the competencies required.
Is everyone carrying out the relevant and acceptable CPD? Understand what relevant and acceptable CPD training is and make sure all your staff has sufficient access throughout the year.
Does next year’s budget include a figure for the unexpected? Ensure you have a realistic budget for the requirements of your staff?
Do supervisors and team leaders need training to support the competence of your people? Be assured your supervisors and team leaders understand their duties and responsibilities for ensuring that their staff members are competent.
Does the appraisal process include competence? Know that your appraisal process for staff members cover their required competencies.Working with FSTP will take away the pressure of ensuring your firm is not only prepared for 2018, but successfully effective in 2018.

Contact us today to discuss possible support for your T&C scheme. We’ve helped many established companies optimise and develop an effective T&C scheme through conducting gaps analysis. We’ve also worked with new businesses setting up from scratch.

Philippa Grocott

Business Development Partner