For specific IT products, it’s not the FCA’s practice to hand out official endorsements. As such, (and rather unfortunately,) there isn’t a ‘stamp of approval’ to look for when shopping around for tech solutions.But of course, the issue of FCA needs to be a top priority when making those decisions. In a whole range of areas, from storing call records, through to managing relationships with clients, the correct approach involves considering carefully what the specific regulations say, and choosing a product that will keep you on the right side of those rules.Traditionally, the FCA (and its predecessor, the FSA) has focused its attentions largely on regulated functions and processes - the ins and outs of fund administration and complaints management, for instance. There has been less detailed guidance on the IT infrastructure and tech tools that are crucial for delivering those processes in real life. Recently however, we’ve seen some movement on this; especially with the rollout earlier this year of finalised guidance on what firms should look for in a cloud provider, for instance.
With this in mind, here’s a rundown of the type of solutions that are likely to keep you in the FCA’s good books…
Managing customer relationships
Salesforce deserves special attention here, not least because the FCA is itself partnered with this CRM specialist for its own communications functions.
We are not saying that all regulated firms should follow the FCA’s lead here; choice of CRM software should be made with reference to your firm’s particular needs. However, choosing a big, reputable provider along the lines of Salesforce helps you stay on the right side of the rules. The recent cloud guidance sets out the questions you should be asking here, such as whether it has a solid reputation for stability, security and adherence with international standards. Going with a reputable name helps you avoid taking unnecessary risks in these areas.
Even if you see no need for a ‘full fat’ off-the-shelf CRM system, managing client communications should be a crucial concern - especially when it comes to complaints. Recent revisions to the rules in this area highlight the need for the ability to capture, log and track complaints across your firm - not least, to build up the necessary data to submit your annual ‘complaints return’. Specialist complaints handling software such as Usefulfeeback and Workpro provide a direct solution to this.
We recently highlighted how Office 365 can be safely deployed by FCA-regulated firms. That’s not to say, however, that its existing features shouldn’t be enhanced to ensure full compliance. This is especially the case when it comes to Outlook - and your ability to store large quantities of email correspondence securely, without risk of corruption or alteration in line with the regulations. Mimecast is one such company offering secure, yet accessible and searchable archiving of emails.
Special considerations apply to banks, stockbrokers, investment managers and financial commodity derivatives firms. Here, COBS 11.8 requires firms to retain records not just of electronic communications but also transaction-related telephone conversations. Providers such as Oak have a proven track record in compliance-centred telephony recording.
Whichever tools and platforms you choose to deploy, full accountability for discharging your regulatory responsibilities remains with your firm. For instance, if the FCA demands certain historic records, it’s not possible to escape responsibility by, for instance, blaming a failed migration process or a problem with a storage vendor for failure to produce them. Bear this in mind and choose wisely - paying special attention to the vendor or support partner's track record in dealing with FCA-regulated firms.
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