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After x6 weeks of the “NEW-NORMAL”, I suggest the “OLD-NORMAL” needs to start being thought about again. These “NORMAL-NORMALS” include addressing certain matters that sit outside of the day to day compliance and risk oversight (board meetings, committee meetings, CMPs, etc.).  These matters are codified specifics in the Code of Practice (CoP)

(CoP) – General and can be applied across all industry functions (albeit MSBs do not seem to have to do much.!!)

  • 1.4 All aspects of corporate governance arrangements must be subject to appropriately regular review to ensure their continuing adequacy in light of the registered person’s business activities and risk profiles and include a PERIODIC SELF-ASSESSMENT, or external assessment, of the board’s effectiveness.
  • 3.1.3 Assessment, on at least an ANNUAL BASIS, of the extent to which compliance risk is managed effectively;
  • 2.6 Where a registered person controls client [fund] money it should implement an independent review of the controls over client [fund] money on, at least, an ANNUAL BASIS:
  • 3.1.3 Assessment, on at least an ANNUAL BASIS, of the extent to which compliance risk is managed effectively;
  • 2.5 A registered person must undertake a PERIODIC REVIEW of the internal systems and controls to ensure that they continue to work effectively. (& to ensure compliance with the Applicable Rules]
  • 4.3.1 PERIODIC REVIEW of the accessibility and condition of paper and electronic records & PERIODIC TESTING of procedures relating to the retrieval of records.
  • 6.8 A registered person must have in place a proper, documented, remuneration policy for directors and employees, and must review it PERIODICALLY.

(CoP) – TCSB

  • 6 Any delegation of duties or powers, whether by power of attorney, formal agreement or otherwise, must only be entered into with an appropriate person for a proper purpose. The registered person must:
  • 6.3 Where the delegation is revocable, include within the documentation an expiry date or a requirement that the relationship with the appropriate person is formally reviewed on a PERIODIC BASIS;


  • 10 on an ANNUAL BASIS, a registered person, must review the due diligence and suitability criteria of the products and their investment service providers, in relation to the investment services provided to its clients. When taking on multiple clients from an existing service provider, this review must be undertaken within one year of the date of the transfer.
  • 24 – 2.26 - Best Execution - Note. 4   A registered person should have policies to ensure appropriate transactional cost analysis, including top trading venues, is reviewed at least ANNUALLY.

Comsure can assist with one or more of the above – please contact at any time


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