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Scope of Services
The provision of compliance consultancy services which include: -
I. Assessment of Compliance Policies & Procedures
The main objective of the assessment is to ascertain if the licensed/exempt Financial Adviser's ("FA") internal policies and procedures are compliant with the relevant legislation, in particular the Financial Advisers Act ("FAA"), the Financial Advisers Regulations ("FAR"), Notices and Guidelines.
There are 4 main areas that FCCC provides assessment on: -
- Switching of Designated Investment Products & Use of Introducers
- Anti-Money Laundering and Countering the Financing of Terrorism (AMT/CFT)
- Recruitment, Training & Competency
- Complaints Management & Reporting of Misconduct
The assessment will typically cover:
- Review of the existing policies and procedures,
- Whether the existing policies and procedures are complied with (non-compliance incidents will be highlighted, if any), and
- Recommendations to strengthen the existing policies and procedures.
II. Compliance Audit
The main objective of this audit is to ascertain if the FA representatives indeed provided their financial advisory services in accordance to the FA's advisory and sales policies and procedures.
The compliance audit will typically include reviewing the sales documentations to check whether the following has been done:
- Necessary disclosure
- Know your client
- Needs analysis
- Reasonable basis for any recommendation
- Documentation and record keeping
Upon completion of the audit, a report with the findings and recommendations to improve or tighten up the advisory and sales process will be given to the FA's management.
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