Family Relationships Under Fire

Lessons from the Front Line

I sat glued to the news conference as three wounded soldiers – Marine Lance Corporal Joshua Menard, Army Staff Sergeant James Villafane, and Army Sergeant Charles Horgan – recalled their experiences of coming under fire from Iraqi troops in civil dress at the city of Nassiriya. Villafane and Horgan told about being stuck by an incoming missile.
As I watched, I, too, was stuck … by the similarities between their experiences on the battlefield and those of stressed-out families, "under fire." Listen and learn from their experiences.

Lesson 1: DO NOT BE CAUGHT OFF-GUARD; PREPARE.
"We were told that when we were going through Nassiriya that we would see little to no resistance.
Realistically anticipate and prepare for the inevitable challenges your family will face. "Prepare for the worst," while guarding the positive attitudes that "create the best."

Lesson 2: YOUR GOOD INTENTIONS CAN BE MISUNDERSTOOD.
Villafane commented, "The amount of resistance, some of it I do not understand. I mean, we're there to help them to get them out of the statute. we try to give them. We try to treat them fairly. "
Know this! You can be misunderstood by family members, even when you have the best of intentions and are trying your best. Parents, it takes courage to make wise, yet unpopular decisions.
On the other hand, "meaning well" can not substitute for "doing well." Check your actions, being willing to openly consider what it's like to be on the other side of you.

Lesson 3: DO NOT MAKE MISTAKES ABOUT WHO YOUR ENEMY IS.
A group of Iraqi soldiers dressed in the civil robes of nomad Bedoins opened fire on Menard as he and six other Marines approached them on a bridge in Nassiriya. Military enemies, pretending to be harmless.
Even more appalling was the account of the American soldier who allegedly pulled the grenade that killed and injured people in his own troop. Yet, we've lost our sensitivity to the shock of similar responsibilities in our own families … daily "grenades" of hurtful words and destructive actions.
"Out there", there are so many enemies to the wellbeing of family members. How can we hope to combat those if we spend our time fighting within our own ranks? What can you do today to mend family rifts?

Lesson 4: DO NOT PANIC WHEN TROUBLES COME.
Sergeant Horgan told about how he worked to stay calm, though he had just been wounded by the enemy missile. He said that he was grateful that "training kicks in" and that he was able not to panic. "My foot may be gone, but I gotta move."
When you are faced with an unexpected and disturbing challenge in your family, do not panic, reacting impulsively. Seek help if necessary. Do not say or do things that make the situation worse in the long run.
Stop … think … plan … then act.

Lesson 5: PROTECT YOUR FAMILY MEMBERS, NOT JUST YOURSELF.
The way these well-trained, courageous soldiers behaved under fire is, to me, the greatest of our lessons in family teamwork. Listen in, and examine your own habits and actions.

Horgan, whose right leg and foot were ripped open when he was blown from his gunning position, described his thoughts when he saw the incoming miss: "Oh, my God, I'm gonna die.

Villafane quipped, "It's not being shot at that bad. (Can you refer to that?) Despite the horror of what they had experienced, the three wounded men all said they felt a sense of guilt about leaving friends behind in Iraq. Horgan told reporters, "I'm relieved that I'm out … Nobody can be shot and say, 'Wow, I really want to go back out there. But I'm kind of sad that I'm not with the guys who protected me. My friends protected me when I needed them.

Complete Assistance in the preparation for the implementation of the SMR/CR can be obtained from us at Complaince Consultant Where we have experience in the banking sector from 2015/2016.

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Money Laundering Regulations 2017 Changes

Money Laundering Regulations 2017 Changes
As you know, the 26 June 2017 saw the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”) came into force, having been made, laid before Parliament and approved all on 22 June 2017.

Regulated businesses are now faced with the inestimable task of ensuring both their firm-wide and client-specific risk assessment processes and procedures are sufficiently robust to comply with MLR 2017 – after the commencement date.

If you use an external Compliance Service, they may well have provided you with an update on the legislation before it came into force, however, anyone who used the original draft in the belief that they would be the final rules will have failed to identify key points that are required by firms, that have been changed or were introduced in the final legislation.

Questions You Need To Ask

1. Have we reviewed the definitions and procedures in accordance with the MLD4?
2. Have we updated the CDD/EDD/SDD and Beneficial owner sections?
3. Have we trained our staff on the changes?
4. Is our policy up to date?
5. Is our policy approved by the board?
6. Would our AML/KYC/FC preparations or current arrangements stand up to independent external scrutiny?
7. Do you need to review the ‘state of play’ within your firm?

If the answer to ANY of these questions is “NO”You Need Our Help.

After a comparative analysis of the draft Regulations and the final MLR 2017 from the draft published by HM Treasury in April 2017 there are key differences which we have identified below.

Risk Assessment & Review
At your business level, two risk assessments are required. A business-wide risk assessment of money laundering and terrorist financing geographical features, transactions, products and delivery channels, as well as a specific risk inquiry prior to the commencement of each client relationship and, following a consideration of customer type, indeed, during the course of the relationship.

Governance Requirement
Regulation 19 of the Act shows a positive duty on regulated businesses to “regularly review and update” such policies and controls has been inserted in Regulation 19( 1)(b). Businesses will also be required to maintain a written record of all changes to AML policies, controls and procedures made because of a review plus all “steps taken to communicate” the changes to staff. This means that your version control is now of paramount importance. A similar requirement applies in Regulation 20 to parent companies in the UK, falling within the scope of a “relevant” (regulated) person.

Internal Controls
Alongside the requirement to implement and regularly review AML policies and procedures, is a requirement in Regulation 21 that regulated persons implement internal controls applicable to employees engaging with compliance matters. Previously, the draft Regulations required a firm to “carry out screening of relevant employees and agents” at regular intervals. “Screening” relates to assessing the skills, knowledge and expertise of a particular individual. The final version of the Regulations, however, has slightly lessened the compliance burden in one respect by dropping the reference to “agents” in Regulation 21.

Training records
A duty to maintain written records of training provided to relevant employees, which practically would include all fee earners and those in the Compliance function, also appears in Regulation 24. No such duty featured in this April’s draft Regulations.

Special Offers For Limited Number And/Or Date
If you want to get an up-to-date AML & CTF Manual, please click on this link (http://aml-compliance-manual-ofac-sanctions-ctf.co.uk) and use the code “CCMLD4” in the payment box.

Hurry because this only valid for the first 25!

If you want to take advantage of our policy checking offer, go to our special offer HERE but hurry, this is only on sale until the 31st August!

Money Laundering Regulations 2017 Changes

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What the FCA found when it did a Suitability Assessment of the IFA Sector in 2017

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What the FCA found when it did a Suitability Assessment of the IFA Sector in 2017

The Independent Financial Advice (IFA) sector was given a clean bill of health by the FCA in May 2017. Or was it?

A suitability review of 1,142 separate pieces of advice given by 656 firms against the rules in the Conduct of Business sourcebook showed that in 93.1% of cases, advice provided was suitable.

Interestingly enough, and one that the regulator has now agreed, they used a simple balance of probabilities of extrapolation of the data in their assessments, across the industry. This does not mean that the processes used to arrive at the suitable advice were correct, simply that the advice provided was more than likely to be what the client should have been recommended.

You have to dig your way through appendix 1 to find that 481 of the 656 firms in the sample had a single file examined. The file was chosen randomly, from advice given in 2015. We are pretty sure if an IFA told the FCA that its own quality assurance consisted of one file it would get a sudden amount of regulatory attention.

What, if any, assurance can consumers understand from this? Simply that in 2015, 481 firms of IFAs gave a single good piece of advice. The advice in 2013 could have been terrible and 2014 may not be described in any positive way.

So the next question must be; how is this reflected within the industry?

In January 2017, the Financial Services Compensation Scheme (FSCS) issued a statement, announcing three supplementary levies for 2016/17, totaling ₤114mn. Its Chief Executive explained:

” We will ask life and pensions intermediaries to pay their share of an additional ₤ 36m to fund compensation for the high numbers of SIPP-related claims we are continuing to receive, but also need to trigger a cross subsidy for the first time. These claims relate to advice to switch pension funds into high risk investments. We previously flagged the potential for high costs here … And we currently expect a deficit of ₤ 15m on our home finance intermediation account due largely to the failure of one particular firm that gave bad advice to engage in risky property investments alongside mortgage advice.”

The State of Play

The FCA says everything is fine. The FSCS says it needs more money due to poor advice surrounding self-invested pension plans, and pension transfers. In 2017 alone, the FSCS declared 90 firms in default. A lot of these were IFAs whose professional indemnity insurance claims limit were exhausted, and who couldn’t fund the Financial Ombudsman Service’s awards.

If you were running an IFA business, would you be telling everyone that the FCA are happy with ALL adviser’s and their suitable advice, or would you keep quiet in case someone digs deeper and finds the methodology was questionable?

We can help you with all your compliance support issues

 

What the FCA found when it did a Suitability Assessment of the IFA Sector in 2017

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Our compliance consultants are subject-matter experts and assist clients from a broad range of areas, these include, but are not limited to;

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How Can You Adapt To The Growing Rate Of Regulatory Change With Confidence?

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How Can You Adapt To The Growing Rate Of Regulatory Change With Confidence?

How Can You Adapt To The Growing Rate Of

Regulatory Change With Confidence?

Regulatory Change Management
For three years now we have provided a fundamental and key approach to the regulatory change management process, offering clients a clear and transparent understanding of their business lines, referenced against the regulators handbook and effectively mapping operations ensuring that clients can easily and simply identify areas impacted whenever their is a relevant regulatory development.

What We Cover Here

  1. Tracking & Monitoring Regulatory Events
  2. Mapping & Assigning Regulatory Developments
  3. Evaluate and Identify Impact
  4. Demonstrate Compliance

Track and monitor regulatory events
Compliance Consultant Regulatory and Risk Based Footprint Mapping, is a spreadsheet based solution that is created covering all of your operational areas to provide you with comprehensive coverage of legislative and regulatory content “at a glance”.

You can easily identify if changes occur in a specific handbook not only which areas are impacted (Level 0 – Regulation) but also on a level 1 basis for Business Conduct and Business Regulation, right to the chapter level. With handy hyperlinked text, you can go straight to the handbook section that applies to you.

Additionally, for 6 months you will be a member of our “Informer” regulatory awareness service, keeping you up to date with articles and posts by those who know what’s what in financial services.

You can also sign up for our free weekly “Regulatory Specialist” digest newsletter, delivered to your inbox http://paper.li/ComplianceConst/1411645553#/ or from our blog at http://www.complianceconsultant.org/blog/compliance-news/

Map and assign regulatory developments
Regulatory and Risk Based Footprint Mapping provides simplified mapping capabilities and complete taxonomy support, providing clean and effective line of sight for emerging regulatory issues. This ensures relevant information can be sent to the right stakeholders to manage and helps minimise compliance risk.

Through this connected approach, this helps your firm foster a deeper understanding of the regulatory developments affecting day-to-day business processes and reduce your total compliance effort.

With Compliance Consultant Regulatory and Risk Based Footprint Mapping you have the added assurance that your regulatory requirements are mapped across the entire enterprise. You can set up templated emails to automatically notify business owners each time a regulatory change occurs, and teams can easily assess who is in charge of particular developments, what level of risk is associated with that change, and any key information, without the need for expensive and often intrusive software.

Evaluate and identify impact
Once your organisation has established that the relevant regulatory developments are being tracked, Compliance Consultant Regulatory and Risk Based Footprint Mapping then assists your compliance teams perform impact assessments to determine which business units, controls, policies, and procedures were affected by any change.

Demonstrate Compliance
Added to this, you can also build in as a standalone declaration of all the impacted areas and provide evidence of compliance, suitable for audit or external inspection (such as risk rating agencies, stakeholders or committees by adding in the Compliance Charting Tool. By using this declaration of compliance as a central register and provider of comfort for senior management, you can easily update it as and when the regulations change.

By using version control, this full process ensures you have a complete audit trail to evidence to regulators what steps were taken to remain compliant.

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Average U.S. Household Debt is Higher Than You Might Think

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Average U.S. Household Debt is Higher Than You Might Think

Americans have more monthly payments today than ever before. Mortgages, credit cards, student loans, medical bills. You name it, somebody is paying on it. Whether you have just one of these payments or are chipping away at all of them month by month, your debt may be getting smaller at a slower rate than you think.

Halfway through 2017, Americans have already borrowed more money than at the height of the 2008 credit bubble. This has lead to higher debt balances that come with an even bigger debt builder: Interest.

Interest rates, while staying relatively low, and crushing most Americans in debt. Credit card debt is the most commonly known issue with excessive interest rates. With the average credit card balance hovering just under $17,000 per household, the average credit card interest rate of 15.59% adds an additional $2,766.18 a year. With most Americans paying the minimum payment, the interest rates accumulate to amounts quite a bit higher than initially borrowed. Even with the minimum payment, the balance can continue to grow due to the high-interest rate.

Credit cards carry the highest interest rate, but mortgages are the sneaky debt builders in the group. Carrying an average interest rate just under 4%, the damage doesn’t seem as devastating as credit cards. Apply that low-interest rate to the total U.S. mortgage balance of $176,222, and you are left with almost a whopping $7,500 in interest payments annually. At three times the annual cost of credit cards, mortgages can add up to an additional $200,000 or more over the course of a 30-year mortgage.

Choosing debt widely can have a significant impact on your wealth. Low interest-rate options like student loans and car loans can still have a substantial impact on your long term wealth. On Investment Zen,  this infographic breaks down the average U.S. debt and some helpful tips on how to break free.

 

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The Responsibility of Compliance Directors Is Growing And It Is Vital They Have Their Finger On The Pulse.

The Responsibility of Compliance Directors Is Growing And It Is Vital They Have Their Finger On The Pulse.
Buy Your Copy Now – Paperback or Kindle!

The Responsibility of Compliance Directors Is Growing And It Is Vital They Have Their Finger On The Pulse.

Instruction book on how to perform a role under UK regulatory requirements for a firm to meet compliance.

As a UK Financial Services Regulatory Compliance Executive who desires to be sure they have all bases covered before any regulatory visit; or maybe wish to know the secret tips of compliance risk assessments and business or operational risks; or perhaps are new in the job and want insights into hot-topics, enforcement and regulatory methodologies and best practice. If so then the “Compliance Manager Guidebook & Reference” is written for you.

Regulatory Compliance is constantly changing and many people need to know; What do the most recent changes mean? What changes have happened to the regulatory Handbooks? What effect does this have on the sales process? Does the documentation have to be adjusted? Does the sales process have to be amended? Whenever these questions are asked, everyone turns toward “compliance” to find out. If you are new or an old-timer, you have to know what the latest changes are and the best ways to apply the requirements to your firm. If you need any of this and may want to develop the role of the compliance officer within the compliance function or the entire firm then help is at hand.

If you are hoping to discover the affect on compliance and identify areas that cause concern to most compliance professionals, then you’re about to discover how to start improving, today! In fact, we will deal with a number of aspects of the role of the Compliance Manager concerning the regulators and the regulators current perspective and hotspots, by having this Ebook “Compliance Manager Guidebook & Reference”, the most suitable selling Ebook of it’s type, gives you the answers to 17 important questions and challenges every Compliance Manager faces, including: The regulatory terrain; how did this evolve to today’s landscape? How do you map your firm’s actions to the compliance universe? Good and bad compliance and forming a compliance charter. What do you have to perform a Compliance Risk assessment? How do you involve senior management and other departments in their compliance responsibilities? … and more!

Whilst this guide is designed to provide a medium level of information, it is not a Janet and John Guide. We have not, as an example entered into the basics of financial promotions or suitability, completing fact finds or writing suitability reports as there is already help and guidance available at that level. We do not describe how to complete a regulatory online return as it is assumed that you are already an established financial services professional and have been involved in compliance for at the very least two years. So, if you’re serious about improving your role as the compliance officer and identifying good and bad practice and the affect on compliance within your firm then you need to grab a copy of “Compliance Manager Guidebook & Reference” now, because the leading compliance and business risks consultant, Lee Werrell of Compliance Consultant (http://www.complianceconsultant.org), who has over 25 years experience in financial services and compliance (and is a Chartered Fellow of the CISI – FCSI) will reveal to you how every a Compliance Manager can succeed in establishing themselves, and; Provide meaningful data, Deal with inquiries in a professional manner whilst remaining consistent in the answers, Maintain adequate governance throughout the firm, Create a single contact point for the regulators, Know the Approved Persons regulations, Know where to search for the relevant rules or guidance, Plan for regulatory visits and communicate effectively with the regulator and ensure your firm remains compliant in every aspect.

Any purchasers of this book will be entitled to a FREE copy of the revised edition due in early 2018. Simply send proof of purchase to info@complianceconsultant.org.

August 2017 Offer

August 2017 Offer

We all know that the summer months can be quiet for IFAs and what better time to get those awkward jobs dealt with?

At Compliance Consultant we also know that whether you are independent or restricted, there are a number of issues that might need addressing.

The “umbrella” compliance support companies provide a great service, but the FCA doesn’t approve of  downloadable templated “Disclosure Documents” or “Suitability Reports” where they are not personalised sufficiently and contain TOO MANY IRRELEVANT FACTS!

“We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure …….. further work is required by the sector”

The FCA stated in their report on “Suitability” in May  that “We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure and further work is required by the sector to improve the initial disclosure (includes firm’s costs and services).”

Having met with the FCA Supervision Team (authors of the report) recently we have a good handle on what they mean and what they hoped to see already in place. Additionally there was also a great deal of discussion around the suitability letter construction and what content should be included.

Regarding the Senior Managers & Certification Regime, (https://www.fca.org.uk/firms/senior-managers-certification-regime/solo-regulated-firms) we have already worked on this for banking groups and know what is involved, the final tweaks are awaited but

In the details released on 26th July 2017, the FCA said the requirements will include “responsibilities maps, handover procedures, and will need to make sure that there is a senior manager responsible for every area of their firm”.

This means that your procedures need to be identified, mapped and recorded with owners and relevant controls.

What We Are Offering

To Help You Ensure You Are Comfortable With Your Compliance Affairs, We Have Two Offers;

5 Days Work for the price of 4

If you have a piece of work that needs doing, we will arrange to provide 5 days service either at your work site or from a distance (typically report writing etc) at a 20% Discount if at least 5 days work is booked.

What Does This Mean?

This means simply whereby we might normally charge in the range of £500 to £1,200 for a days’ consultancy work of one or more consultants, over a week that would be £2,500 to £6,000

with our offer that is reduced to £2,000 to £4,800 and no VAT!

As An Extra

We Operate A “Benchmarking Audit” and that is on special offer until 4th August from £2,600 discounted to £2,080 with no VAT!

We can offer these discount ONLY FOR WORK BOOKED IN BY

5.00pm 4th AUGUST 2017

CLICK HERE to register your interest and get a copy of our

“Suitability Guide” absolutely Free!

Don’t want the guide? Need to talk to us straight away? Call 0203 815 7939 now!

Why Not Join Our Free IFA Compliance Advice Facebook Page https://www.facebook.com/groups/IFAComplianceUK/