CLIENT DAY BLOG: Compliance Training - Top 5 Takeaways On Where Do We Go Next?
Simon Mercer, Unicorn ComplianceServe Product Manager, and Julia Kirkland, Partner at FSTP, presented a recap on what's happened so far, looked ahead to what are going to be the hot regulatory topics over the next 12-18 months and answered the biggest question of all, how on Earth are we going to do all this?? Julia even sang a little bit. It was beautiful.
Anyway here are the top five takeaways on compliance training and where we go next...
The Senior Managers Regime and accountability will remain firmly on agenda - last week the FCA fed back on the first tranche of it accountability regulation, which took effect in March, stating that many firms have misunderstood the guidance. In a nutshell, the screw is going to keep turning. With 55,000 more firms due to come under SMR by 2018, Julia's key message to anyone still grappling with the challenges of SMR was do not put it in compliance or HR! It has to be championed by a Senior Manager and driven from the top down. The good news is the FCA is suggesting there won't be a 'big bang' on the next tranche of SMR and Certification implementation, but as we've seen from the first phase a year's gap is nothing in these terms. Which brings us neatly to...
How are you bench marking people ahead of the Certification Regime? - firms who have already had to adhere to SMR regulation only have until next February - that's five months - to put a robust certification process in place. In a quick show of hands amongst the delegates in the room, only one firm who had moved over SMR had already got their certification regime running. Under certification you are asking people who weren’t previously approved persons to take on more responsibility, knowledge etc, so how are you benchmarking these people? What competencies and/or qualifications are you using as a baseline? What are the KPIs and the core competencies required for a role? How are you going to issue that individual with a certificate? And remember the Senior Manager has the ultimate responsibility for saying they've signed that person off. It's a big deal.
What's hot in 2017 and what's relevant to you - Julia outlined how she and her FSTP colleagues had trawled through the FCA's annual risk documentation and picked out what they believe to be the 12 biggest areas of interest over the next 12 months. She did threaten to rap at this juncture also...regardless this is the list.
- Conduct risk
- MiFID II
- Transaction reporting
- Certification Regime
- Business strategy and stress testing
BUT (and note the capital letters), even though some will be more relevant to certain businesses than others, the majority are interdependent on each other. They cannot be taken in isolation.
Modernising your learning approach - in the past we have dealt primarily with compliance departments, but this is changing. Within the L&D community learning is being modernised to move from push to pull learning and getting to point where learners have access to resources and tools to pull as well as utilise what’s pushed to them. This includes introducing more elements of microlearning, in bite-sized chunks that is much more informal and on demand in line with the 70: 20: 10 approach to learning. Unicorn's eCreator authoring tool, built into ComplianceServe, has got a really significant role to play in this. In fact, by Christmas all existing ComplianceServe content will have been re-developed in eCreator, with the smaller chunks of micro learning, to follow. The benefit? By downloading the SkillsServe app learning can take place offline to sync when back online.
There is a brand new generic T&C system now built in to ComplianceServe - we've been building and integrating custom T&C systems and functions for clients for a long time but now there's a generic version for smaller organisations to make use of. This includes:
- T&C Guidance – regulation is only going way way, there will be an ever greater need to evidence competency. Guidance is all about what does T&C mean for an organisation, how do you create a T&C scheme in the first place, what things need do you need to set up a T&C system in ComplianceServe
- Pre-defined forms and workflows
- Offline forms – there is too much to do online for some things. Can be completed, scanned and attached as part of site.
- Pre-built pathways – for e.g. monthly one-to-ones, quarterly action plan and final sign off, can be assigned to both regulated and non-regulated staff (couple of forms different)