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Towards better systems
If you find yourself having to carry out a case review that reveals significant case failure, it is likely that there has been systemic process failure at some level.
This will mean that the firm will have to change its approach going forward to develop systems and controls and management information to be certain it meets in future the relevant outcomes for Treating Customers Fairly that the FSA requires.
To do this requires a good understanding of the FSA requirements and the skills to develop effective new systems and appropriate management information that gives qualitative information on the business being written. The exact design of the system will vary depending on the size of the business and the complexity of its structure, but there are key features common to all effective sales control systems:
- those in the sales case checking role must be independent of the sales adviser;
- there needs to be senior management support for the checkers;
- the checkers should be at least as well trained and qualified as the adviser;
- there needs to be a system of qualitative management information that reports to senior management on the quality of advice. This can include sales checking results, policy lapses, and complaints;
- senior management must have available a process by which they can effectively impact on instances of unsuitable advice; and
- systems need periodically to be subject to independent audit to ensure that they are working effectively.
One needs to benchmark any proposed system against the industry norm, and again an independent view from an agency external to the firm can be of benefit. A firm that needs to redesign its systems and controls would be well-advised to schedule an early audit to ensure that the changes made are effective at achieving the required standards of advice and record keeping.
Contact us to find out how OAC can help you resolve your pension switching review issues.
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