Shock Failings In Firms’ Regulated Complaint Handling Rules

compliance-risk-management-function-consultant-consultancy

complaint management fca system process failure customer service

 

 

 

 

 

 

 Are Firm’s Managing Complaints Efficiently And Learning The Lessons From ALL Complaints, Not Just Cherry Picking The Juicy Ones To Report?

The changes made to the FCA’s complaint handling rules in June 2016 are well documented.

In conclusion:

  • The ‘next business day rule’ has been extended to become a ‘three business day rule’ (where sending final response letters (FRLs) are required).
  • Firms must now send a ‘Summary Resolution Communication’ (SRC) in response to all complaints that are dealt with within three days of receipt.
  • The SRC must confirm that the complaint has been resolved and inform the customer of their rights to refer the matter to the Financial Ombudsman Service (FOS).
  • All complaints must be recorded and submitted to the FCA via their new ‘complaints return’.

The rules are designed to benefit customers by “ensuring that complaints are handled quicker, efficiently and transparently”. Firms do not need to try to resolve complaints on the same day in order to avoid reporting or sending the customer an FRL. Consequently, more time and greater consideration can be given to each individual complaint and the circumstances of the complainant. This should also support a more flexible operating model and relieve some operational triage and case management strains.

Firms lose the ability to resolve complaints without reporting them; nevertheless, where all complaints are logged and reported, firms should have access to management information (MI) that better shows their complaint population, and therefore root cause analysis (RCA) should certainly be more robust- revealing a more accurate understanding of the firm’s performance.

Presumably, there are positives for clients and the sector, but how are firms managing the changes?

WHAT HAVE BEEN THE PRACTICAL IMPLICATIONS FOR FIRMS?
call center-complaint-management-customer serviceTheoretically, where the firm is positive that complaints, which were being closed by the next business day, were identified and resolved fairly (and in-line with regulatory expectations), then the shifting to the new rules should be more straightforward. In this instance, the biggest change for the complaint handling department is logging the complaint correctly, and issuing an SRC to the consumer. This, however, still leads to an immediate need to present systems training to staff, and to update procedures to ensure SRCs are issued to customers in the correct manner.

The new reporting rules mean that there is now a record of every single dissatisfaction handled by the firm, and therefore fair customer outcomes and compliant complaint handling should be demonstrable in every instances. This has exposed some firms’ ability to appropriately identify and handle complaints in their front-line and client service departments, or those who do not handle complaints often. Reasons for this typically include:.

  • A training or capability gap.
  • Conflicting incentive schemes.
  • Inadequate processes and procedures.
  • Inadequate back up and oversight.
  • Issues with company conduct.

Unfortunately, this has also led to the inherent expectation that front-line staff, who might receive complaints infrequently, have the ability to serve as skilled complaint handlers. For some team members, this will feel like a change to their role, so firms ought to provide the appropriate support to individuals for them to execute effective complaint handling that meets regulatory requirements.

Additionally this, the regulatory definition of a complaint- and a firm’s treatment of it- has entered into the center stage. Previously, ‘minor’ or ‘immaterial’ complaints might be quickly dealt with and resolved without too much concern for whether the regulatory definition of a complaint had been met. Now that all complaints are recorded, firms need to be confident that complaints are being identified in line with regulatory expectations, resulting in ‘materiality’ coming into question. This serves to make the understanding of what is and isn’t a complaint an intrinsic part of the process, and comes at the same time as an increased reliance on non-skilled frontline staff to perform complaint handling.

These changes have also meant that firms’ operating models and controls have had to be increased, since added departments and complaint channels should be more closely monitored. Some firms have miscalculated the extent of the required changes.

HOW CAN FIRMS ADDRESS THE CURRENT CHALLENGES?

Firms should reevaluate their complaint handling operating model whilst considering the FCA’s expectations around a ‘fair customer outcome – at the first possible opportunity’, and whilst also reviewing their “risk appetite”. They should be comfortable that complaints will be effectively identified and handled in every front-line area, with relevant evidence of good practice recorded and retained.

Regardless of the process for complaints a firm deems appropriate, as a minimum, complaints ought to be identified successfully by front-line staff, so a level of training, guidance and support is required on an immediate and ongoing basis to reduce ‘knowledge gap’ and ‘skill fade’ threats where complaint handling is not the day-to-day job.

The expectations of staff and the firm should be assessed so as to gain insight on effective ways to align the two. As part of its suite of training pertaining to complaints, firms should also aim to improve their staff members’s contextual knowledge around why effective complaint handling is vital across the industry today. They could also use this opportunity to review their complaint handling culture, and reaffirming the crucial elements of treating customers fairly, where appropriate.

Firms should ensure that they have a clear and, most notably, consistent interpretation of a complaint which gives context and meaning to the idea of ‘materiality’, using a broad spread of real examples in line with their risk appetite.

Firms’ operational controls under the former rules (including quality assurance (QA), training & competence (T&C), MI, RCA and governance arrangements) may never give the full understanding of complaint handling across the company, leading to an increased risk of unjustifiable customer outcomes and regulatory breaches.

Therefore, in order for the firm to show compliant complaint handling to the regulator, these operational controls have to be appropriately broadened (while ensuring a risk-based approach) to give a detailed view of complaint handling in all areas. This causes updated requirements for QA and RCA frameworks, T&C schemes, MI reports, scorecards, training programmes, governance structures and agendas; to name but a few.

Finally, firms should be satisfied that their systems and infrastructure allows them to record, report and handle complaints in line with regulatory expectations. This means ensuring that calls are recorded (i.e. interactions can be evidenced), all relevant individuals have access to the firm’s complaint handling system and the system has the capacity to support effective MI and RCA.

A CONTINUED EXPERIENCE TOWARDS COMPLAINTS EXCELLENCE.

Alongside the initial challenges that were projected at the outset of PS15/ 19 and during the prior consultation, there have been some inadvertent issues arising through the pragmatic implementation of the rules which are more nuanced and tougher for firms to diagnose.

Firms wishing to gain assurance that they are reacting appropriately to these challenges can determine their strategy to the areas above to give themselves a richer picture. It is needless to say perfectly natural that problems should arise when such a significant change is executed, nonetheless it is the ability to react to these challenges with appropriate and proportionate action that will differentiate firms on the market.

If you need assessments of your complaints management, systems and controls or testing of embeddedness of your implementation, contact Compliance Consultant on

+44 (0) 203 815 7939

Questions To Ask [Important] – Regulatory Radar July 2017

featured-Ragulatory-Radar-FCA-July-2017-Mifid-Mifid2

fca-regulatory-radar-2017-july-gdpr-smcr-mifid-mlr2017-mld4

MiFID II Regulatory Pieces Are Falling Into Place With The FCA

The final two pieces of UK legislation implementing MiFID II were laid before Parliament on 26th June which give the FCA powers to make certain of the changes to the handbook rules (such as the financial promotion rules) and to carry out certain administrative tasks linked to implementation (such as setting position limits).

 These are the:

Data Reporting Services Provider Regulations http://www.legislation.gov.uk/id/uksi/2017/699

Markets in Financial Instruments Regulations http://www.legislation.gov.uk/id/uksi/2017/701

With that in mind, I thought I would just remind you of what’s happened and what’s on the radar that you may need some assistance with the planning and implementation of.

See Our Special Offers At The Foot Of This Article

Save Money On Your AML Manual & Governance Review!

These areas are;

  1. 4th ML Directive was effected on Monday 26thJune and becomes the Money Laundering Regulations 2017 and affects all businesses, taking over from the 2007 version. This should have already been addressed with the appropriate changes to your AML policy and procedures, but seems to still be causing some firms slight issues, especially around their governance & risk identification and mitigation (risk register).
  2. MiFID II (that which we all love) is effective 3rd January and there are some fairly seismic shifts for many asset and fund managers. For advisers, there are several fairly minor but changes that need to be reviewed. There are also some subtly changes that some firms have overlooked such as “best execution” rules and the reporting. Fees and Costs are another area for consideration. As I am sure you are aware, changes to the right governance (CofI, Inducements etc) all need to be in place for the 3rdJan.
  3. I am sure your preparations for Senior Managers & Certification Regime (SMR or SM&CR) due to be rolled out over 2018 across all firms is well underway, despite not yet having the final rules, the foundations are still going to be the same as for banks. This is going to take huge preparation on the part of all sizes of firms, such as mapping their rules, responsibilities, allocation of roles, appropriate distinctions between functional allocation, appropriate training to directors, NEDs and staff, changes to employment contracts (more in 4 below), breach reporting policy and procedures, Board oversight of conduct related issues, revised KPIs etc, changes to governance and many other aspects that I could bore you with.
  4. Further to 3 above, the SM&CR HR element has to be planned well in advance for SM&CR changes due to employment law legislation. You will need, if you haven’t already, to review the Regulations that Impact People, such as and for example; Threshold Conditions (COND), Principles for Business (PRIN). Senior Management Arrangements, Systems and Controls (SYSC), Fit and Proper Test for Approved Persons (FIT), Principles and Code of Practice for Approved Persons (APER) and Training and Competence (TC).
  5. General Data Protection Regulation (GDPR) This is a European implementation 28th May 2018 ad will take some preparation – especially on the lead gathering, newsletter management, handling, storing and processing of data, appropriate age restrictions etc, disclosure and other aspects of data management.

 

Questions to ask

MLD4

  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?

 

MIFID II

  1. Transaction reporting – Legal Entity Identifiers – Do we understand the requirements?
  2. Information to clients – costs & charges – Are we clear on what changes are required and do we have a clear plan for making those changes appropriately?
  3. Reporting – Are we cear on the new reporting requirements?
  4. Are we happy that our existing systems can provide the new service?
  5. Advice – Are we happy with the new definition?
  6. Suitability – Are we comfortable that oour existing Suitability practices are adequate?
  7. Appropriateness – Are we comfortable that the products we sell are considered “non-complex” or do we need to make changes?
  8. Fair, clear and not misleading – if we provide future performance, do we comply with the new rules?
  9. Communication recording – Are we happy that we have a comprehensive method of recording the content and timings of communications and clearly identify the outcomes accurately?
  10. Inducements – Do we comply with the new rules? Are those we deal with complying with the new rules?
  11. Best execution – Have we made the appropriate changes in our documentation?
  12. Product governance: distribution – Have we enough information to ensure that the products and services we provide are not mis-sold?
  13. Client Agreements – Have we ensured we have a plan to amend agreements and terms & conditions documents appropriately?
  14. Have we trained our staff on the impending changes?
  15. Is our suite of policies up to date?
  16. Are our policies approved by the board?
  17. Would our MiFID II preparations or current arrangements stand up to independent external scrutiny?
  18. Do you need to review the ‘state of play’ within your firm?

 

SM&CR

  1. Have we planned, in good time, for all SMFs & CRs to receive training on the duty of responsibility, reasonable steps and the regulators’ guidance relative to them?
  2. What steps do we need to take to ensure our has the ability to provide and obtain regulatory references for SMF and Certified roles?
  3. Have we mapped our business against the regulator’s handbook so that we are aware of the impacting changes and where/who will be effected?
  4. Are our record keeping facilities set-up to retain relevant documentation for at least six years after an individual leaves the business?
  5. Have we identified potential conduct risks and implemented controls or mitigation measures?
  6. Is our risk register up to date?
  7. How do the board get made aware of conduct issues? (They are responsible for ALL conduct)
  8. Have we prepared a formal and robust documentation of the firm’s governance arrangements into responsibilities maps and statements of responsibilities, setting out board and committee structures, roles, responsibilities & escalation lines?
  9. Have we mapped existing SIF approvals onto the new SMF framework, and identifying staff potentially subject to the Certification Regime.
  10. Have we trained our staff on the impending changes?
  11. Would your SMR preparations or current arrangements stand up to independent external scrutiny?
  12. Do you need to review the ‘state of play’ within your firm?
  13. Is our Conduct Policy up to date?
  14. Is our policy approved by the board?

 

GDPR

Do we as a company understand;

 

  1. WHY the personal data processed?
  2. Precisely WHOSE personal data is processed?
  3. For each data management process, WHAT and WHEN is personal data processed?
  4. And finally, precisely WHERE is personal data processed?
  5. Is Senior management aware of and regularly discuss data protection?
  6. Are our Data Protection policies and procedures (including retention and disposal schedules);
  • in place and appropriately approved?
  • adequately monitored?
  • clear and robust compliance trail?
  • regularly reviewed adequately?
  • communicated to staff?
  1. Are our Information Security policies and procedures:
  • in place and appropriately approved?
  • adequately monitored?
  • clear and robust compliance trail?
  • regularly reviewed adequately?
  • communicated to staff?
  1. Do we have formal mechanisms in place to identify breaches and handle incidents;
  • in place and appropriately approved?
  • adequately monitored?
  • clear and robust compliance trail?
  • regularly reviewed adequately?
  • communicated to staff?
  1. Do we have clear and accessible fair processing information given to individuals?
  2. Are all our new new projects and initiatives;
  • “privacy-proofed” at the planning stage?
  • reviewed during development, testing and delivery stage, i.e. pre- and post-implementation?
  • ‘Privacy impact assessments’ are conducted when necessary?
  1. Have we trained our staff on the impending changes?
  2. Would your GDPR preparations or current arrangements stand up to independent external scrutiny?
  3. Do you need to review the ‘state of play’ within your firm?

These issues will not be changing any more, if these are not addressed immediately by firms spending a little money now, they are going to be spending absolute fortunes at the last minute. All firms will have to demonstrate “on demand” that they have everything in place.

You may find these links useful http://www.complianceconsultant.org/so-remarkably-simple-yet-detailed-and-thorough-compliance-risk-management-reference-system/ and https://www.linkedin.com/pulse/do-you-know-how-impacted-lee-werrell

Any firms that may need assistance with any of these areas can contact us for support on 0203 815 7939. Please be aware that our resources are limited and bookings for this work are already being placed. Depending on the size of your project, discounts of up to 20% are available.

If you would like any further information, please drop me a line.


Special Offers For Limited Number And/Or Date
If you want to get an up-to-date AML & CTF Manual, with 1/3rd Off please click on this link (http://aml-compliance-manual-ofac-sanctions-ctf.co.uk) and use the code “CCMLD4” in the payment box for a full 1/3rd discount! 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 at http://www.complianceconsultant.org/product/regulatory-changes-will-force-governance-reviews but hurry, this is only on sale until the 21st July!

Money Laundering Supervision for Estate Agents – Fees

mlr2017-estate-agents-uk-hmrc-treasury

2017-money-laundering-estate-agents-hmrc-reuglations

You must pay HM Revenue and Customs (HMRC) fees when you register for anti-money laundering supervision.

These are:

  • an application submission fee
  • a registration fee for each premises
  • an annual renewal fee for each premises
  • If you’re a money service business or a trust or company service provider you’ll also pay responsible person fees.
Sign Up For Our Information Service & Get Sent PDFs About How You Are Affected

Check Out Our Other Posts at

Who Must Register – Money Laundering Supervision for Estate Agents 
MLR 2017 – Estate Agents – How It Will Affect You? Part 1 
MLR 2017 – Estate Agents – How It Will Affect You? Part 2 
You must pay a non-refundable application charge of £100 when you first apply to register for anti-money laundering supervision.

Premises fee
When you register you must pay £115 for each of the premises you include in your application.

Annual renewal fee
Towards the end of your registration year HMRC will send you an email telling you to log in to your account to renew your registration and pay your renewal fee.

The renewal fee is £115 for each premises shown on the application at the time of renewal.

HMRC may cancel your registration if you don’t pay your annual renewal fee on time.

Fit and proper test fee
If your business is a money service business or a trust or company service provider a fit and proper test will be included in your application to register with HMRC.

There’s a £100 fee for each responsible person the test is applied to.

How to pay the fees
You’ll pay your fees online when you first apply to register and when you renew your registration online. When you input details of your business, the online service will calculate how much you owe and let you pay the total amount due for each type of fee.

If you’ve not yet registered online
If you’re not registered online and need to pay your renewal fees or a fee for an additional nominated person, there’s a variety of ways you can make your payment.

Firms must have established risk and control self-assessment procedures in place.

How HMRC use the fees you pay
HMRC use the fees to:

provide the advice and guidance you need to meet your Money Laundering Regulations responsibilities
carry out checks to make sure businesses are doing all they need to under the regulations
work with other organisations, for example assisting the National Crime Agency with prosecutions

Professional Help Is Available

Compliance Consultant can help provide you with the tools you need to implement, train and embed the new rules, and we can move quickly, getting your firm and your people up to speed in a short space of time, including training and awareness.

Call us today on 0203 815 7939 or

Get Our Solution

money laundering regulations-what is money laundering-money laundering 2017-hmrc

mlr2017solution@complianceconsultant.org 

Sign Up For Our Information Service & Get Sent PDFs About How You Are Affected

Check Out Our Other Posts at

Who Must Register – Money Laundering Supervision for Estate Agents 
MLR 2017 – Estate Agents – How It Will Affect You? Part 1 
MLR 2017 – Estate Agents – How It Will Affect You? Part 2 

MLR 2017 – Estate Agents – How It Will Affect You? Part 2

money-laundering-2017-hmrc-fca-regulation-impact-how t0

2017-money-laundering-estate-agents-hmrc-reuglations

In This Second Part Of “Money Laundering – Estate Agents” We Finish Off How You Will Be Impacted

Part 5 – Beneficial ownership information

This section applies to bodies corporate and to trustees. It requires corporate bodies to provide detailed information to a relevant person when taking part in a relevant transaction with a relevant person (regulation 42) and requires trustees to inform the relevant person of their status and to provide information to them, and to law enforcement authorities (regulation 43). The trustee is under additional requirements to hold certain information and provide information to the Commissioners for Her Majesty’s Revenue and Customs (” the Commissioners”) in certain circumstances. The Commissioners are under a requirement to hold the information that has been received from the trustee in a register (regulation 44).

Firms must have established risk and control self-assessment procedures in place.

Sign Up For Our Information Service & Get Sent PDFs About How You Are Affected

Check Out Our Other Posts at

Who Must Register – Money Laundering Supervision for Estate Agents 
MLR 2017 – Estate Agents – How It Will Affect You? Part 1 
Money Laundering Supervision for Estate Agents – Fees

Part 6 – Money laundering and terrorist financing: supervision and registration

This section makes provision in regard to supervisory authorities and registration of relevant persons. It states that supervisory authorities are subject to a duty to cooperate with other supervisory authorities, the Treasury and law enforcement authorities and a duty to collect information and facts. Provision is created for the situations in which a supervisory authority may disclose information it holds for supervisory purposes. Regulations 52 to 59 require the Financial Conduct Authority and the Commissioners to maintain registers of certain relevant persons, and impose corresponding requirements on relevant persons to request registration. The FCA and the Commissioners have powers to suspend or cancel the registration of a relevant person in certain circumstances.

Part 7 – Transfer of funds (information on the payer) regulations

This section lays out the supervisory authorities for a payment service provider and the duties of the supervisory authorities. There are only two supervisory authorities for payment service providers: the FCA and the Commissioners.

Part 8 – Information and investigation

This section gives supervisory authorities information gathering powers (regulations 64 to 67), gives the FCA and the Commissioners further investigatory powers (regulations 68 to 69) and makes provision for the scenario in which these powers may be exercised (regulations 70 to 72).

SUPERVISORY OVERSIGHT
HMRC has increased the size of its supervisory teams for Estate Agents and stated that it will be carrying out an increased number of supervisory visits. It is likely that we will see a significantly greater level of intervention and enforcement after the implementation of MLR 2017. Now is the moment in order to get your ship in order.

Part 9 – Enforcement

This section identifies “relevant requirements” for the purpose of these Regulations and gives the FCA and the Commissioners powers to impose civil penalties on anyone who has contravened a relevant requirement. Regulations 83 to 89 provide for criminal offences where a relevant person has contravened a relevant requirement; prejudiced an investigation or disclosed false or misleading information to the supervisory authorities and make provision in regard to criminal proceedings.

BE WARNED
This section therefore does not impose additional requirements or make changes to the operational nature of what you are doing, but all EABs should take heed of the forewarning that regulators are getting tough on non-compliance and failings.

Part 10 – Appeals

This section provides for an appeal from a decision by the FCA under these Regulations (regulation 90), and for reviews and appeals in connection with decisions of the Commissioners (regulations 91 to 97).

Part 11 – Miscellaneous provisionshmrc-estate-agent-mlr 2017-mld4-gdpr-regulation-mapping

Among other things ensures that charges or penalties imposed by the FCA or the Commissioners may be recovered as a debt in civil courtroom proceedings (regulation 98), ensures that the FCA and Commissioners have the capacity to recuperate the costs of their supervision or enforcement action (regulation 99) and establishes obligations on various public authorities to disclose any suspicions they may have or money laundering or terrorist financing (regulation 100).

Firms must have established risk and control self-assessment procedures in place.

CONCLUSION
The new money laundering regulations represent a substantial change to the way all firms must manage the potential of financial crime. What we see in this version of the regulations has produced significant changes and in this accelerated time-frame requires firms to be proactive.

What should you do?
HM Treasury has left little time for firms to acclimatise to the new regulations and with the June deadline fast approaching, firms must act now to ensure they understand and adopt the new rules in time.

Compliance Consultant can help provide you with the tools you need to implement, train and embed the new rules, and we can move quickly, getting your firm and your people up to speed in a short space of time, including training and awareness.

Call us today on 0203 815 7939 or

Get Our Solution

money laundering regulations-what is money laundering-money laundering 2017-hmrc

Sign Up For Our Information Service & Get Sent PDFs About How You Are Affected

Check Out Our Other Posts at

Who Must Register – Money Laundering Supervision for Estate Agents 
MLR 2017 – Estate Agents – How It Will Affect You? Part 1 
Money Laundering Supervision for Estate Agents – Fees

Who Must Register – Money Laundering Supervision for Estate Agents

mlr2017-estate-agents-uk-hmrc-treasury

The New Money Laundering Regulations 2017 are due to be effected from 26th June 2017… Are You Registered?

2017-money-laundering-estate-agents-hmrc-reuglations

Who must register
You must register with HMRC if your business carries out any activity defined as estate agency work.

This includes things like:

  • sending out property details and arranging viewings
  • offering personal advice to potential sellers or buyers
  • answering questions from potential sellers or buyers
  • passing on details to customers

Businesses that must register include:

  • high street residential estate agencies
  • commercial estate agencies
  • property or land auctioneers
  • land agents
    relocation agents, property finders, private acquisitions specialists
  • business brokers or transfer agents brokering the sales or transfer of client businesses to third parties
  • a solicitor’s property centre in Scotland

Sign Up For Our Information Service & Get Sent PDFs About How You Are Affected

Check Out Our Other Posts at

MLR 2017 – Estate Agents – How It Will Affect You? Part 1 
MLR 2017 – Estate Agents – How It Will Affect You? Part 2 
Money Laundering Supervision for Estate Agents – Fees

You don’t need to register if you’re:

  • a lettings agent only carrying out lettings work
  • an auctioneer already registered with HMRC as a high value dealer
  • publishing adverts or distributing information, for example in a newspaper
  • an intermediary, like an internet property portal for private sales, allowing private sellers to advertise their properties and letting sellers and buyers to contact each other (but only if you do nothing else covered by the general definition of estate agency work)
  • a solicitor carrying on estate agency work as part of that practice as a solicitor, and not as a separate business
    An estate agency business may be regulated by the Financial Conduct Authority (FCA) for another purpose, for example because they provide consumer finance or hire purchase services. In this situation HMRC and the FCA will consider the possibility of a single supervisor overseeing the anti-money laundering arrangements. Supervision for individual businesses will be looked at on a case by case basis.
  • If you’re an appointed representative of a business that’s authorised by the FCA, then the FCA won’t be your supervisor and you must register with HMRC.

estate agent-hmrc-fines-aml-money-laundering-how-to-help-fcaAdditional guidance
HMRC has published guidance for estate agency businesses on how to comply with their obligations under the money laundering regulations and related legislation.

The guidance explains what businesses must do to protect themselves from the risks of money laundering and terrorist financing and how to report suspicious activity.

What happens if you don’t register
You may receive a penalty if you don’t register a relevant business. This includes carrying on business as an estate agent:

  • without being registered
  • after your registration has been cancelled

The amount of the penalty will depend on each individual case. They will take into consideration:

  • whether you told HMRC that you’re not registered or HMRC has discovered it
  • your reasons for not registering
  • whether you have had any previous warning or penalties
  • They may also take other factors into consideration.

When and how to register
You must register with HMRC before carrying on any activity as an estate agency business and pay the necessary fees.

Apply to register with HMRC.

Annual renewal
At the end of each registration period we’ll send you a renewal notice inviting you to renew your registration by paying the annual fee on all your listed premises. If you don’t need your registration to continue then you should notify HMRC.

If you don’t pay the correct renewal fee then HMRC may terminate your registration and remove your business from its anti-money laundering register.

Don’t Forget: Firms must have established risk and control self-assessment procedures in place.

Compliance Consultant can help provide you with the tools you need to implement, train and embed the new rules, and we can move quickly, getting your firm and your people up to speed in a short space of time, including training and awareness.

Call us today on 0203 815 7939 or

Get Our Solution

money laundering regulations-what is money laundering-money laundering 2017-hmrc

SIGN UP For Our Information Service & GET SENT PDFS About How You Are Affected

Check Out Our Other Posts at

MLR 2017 – Estate Agents – How It Will Affect You? Part 1 
MLR 2017 – Estate Agents – How It Will Affect You? Part 2 
Money Laundering Supervision for Estate Agents – Fees

 

A Culture of Discipline

A “culture of discipline” is a phrase used by Jim Collins (Good to Great) in his study of great companies. All of the great companies, those that far outperform others, have a culture of discipline. This does not mean that they spend their time disciplining people. When you have a culture of discipline you rarely need to discipline people.

A culture of discipline is not about punishing people, but it is about control. It is about self control. Disciplined thinking leads to disciplined action. All greatness, whether it be in athletics, music, art, business, leadership, healing arts and sciences, teaching, or sales, is a result of discipline.

Whether we are talking about an individual or an organization, it all starts with the question: “Who are you and what is your purpose?” Your purpose is found at the crossroads of that which you are passionate about and that which you are good at. Once we are clear about our purpose and the kind of person and/or organization we are, then we need to discipline our thinking in order to achieve it. Thoughts and behaviors that contribute to the purpose are then nourished and expanded.

Most people, and most organizations are undisciplined. We entertain thoughts in our minds that contradict our purpose. We allow behaviors in ourselves and others that should be unacceptable. In a culture of discipline we are clear about who we are and where we are going. We address contradictions honestly, first in ourselves, and then in others, and resolve them.

A year ago I wrote in this newsletter about two very different businesses, one who has a culture of discipline and one who has not. Schulers Books and Music, a local bookstore and cafe is my example of a culture of discipline. At one of the stores I often see the manager out on the floor. Whenever a customer approaches him, he drops everything and serves the customer. I always receive cheerful and helpful service whenever I go there.

A chain restaurant I visited, called Steak and Shake, does not have a culture of discipline. I walked in to get a take out order and could not get served, or even acknowledged. I wrote to the corporate office of Steak and Shake and received a cursory reply.

The difference between these two businesses is that at Schulers, people think a certain way, and act in alignment with those key thoughts. These are thoughts about valuing customers and offering excellent service. At Steak and Shake, people are on their own. They have not been taught how to think, and thus behave, in alignment with the organization’s purpose. You may or may not get lucky and get good service. At Schuler it is not luck; it is consistent great service rooted in a culture of discipline. Embedded in this culture is a deep love for reading and for community that is evident in their consistently great service.

I worked with an organization where the senior leaders loved their work and worked very hard. They saw themselves as disciplined. Yet, they were very undisciplined. Leaders in this organization each went in their own direction. Some of them were noted for being unapproachable and cranky. Others avoided all conflict and said “yes” to everything. Another was known for flying off the handle whenever he felt threatened. All of these managers were talented people. Discipline is about practicing the thoughts and behaviors consistent with your purpose and your goals. It is about holding yourself accountable when you are inconsistent. Much of the talent and hard work of these managers was dissipated because thinking and behavior were not in alignment with purpose and values.

In a culture of discipline we live in alignment with our purpose and in accordance with our values regardless of what is happening in the world. A culture of discipline is responsive to whatever happens. A non disciplined culture has knee jerk reactions to both crisis and opportunity. This is because the motivator in these non disciplined cultures is fear. In a culture of discipline you are motivated by love–love for your purpose; love for those whom you serve; and love for your values. You live from the inside out. This makes you more stable, yet responsive to what is happening around you.

When opportunity presents itself, you don’t grab for it. You think about it. You ask: “Does this fit with my/our purpose? Is this something I/we are willing to do well? Can I/we be passionate about this?” Also, you want to know if it will contribute to your long term viability.

When crisis hits, you respond in ways that are consistent with your purpose and values. No short cuts! Collins wrote in Good to Great, that companies who stuck by their values tended to be more successful. The key, he found, was not in what values they chose, but that they stuck by their values, whatever they were.

In a culture of discipline we make a commitment to our mutual purpose and values. We refuse to allow behavior that is outside that framework. People who violate the purpose and values are given a chance to learn and to change. If they choose not to, they leave. A culture of discipline is not an authoritarian regime where one person is the enforcer. Those organizations tend to fall apart when the dictator leaves. The disciplined culture requires people to adhere to a consistent system, within which they have freedom and responsibility. In a culture of discipline we all help each other to stay on track by reminding each other through ongoing feedback and being a role model.

If you want to see if your organization has a culture of discipline, listen to the stories that are told. Are they stories of accomplishment and appreciation of the efforts of people? Or, are they stories tinged with negativity and criticism? Do people tend to be generous with credit for work well done, or do they mostly talk about what “I” did? Fear based and egocentric stories are ultimately demoralizing and feed negativity. Stories about people going out of their way to help people, and stories where credit is given to others consistently reinforce the purpose, the values, and the way of thinking that identifies the organization at its best. We discipline our minds away from negative and victim thoughts and toward thoughts of appreciation, understanding, problem resolution, and the possibilities to be found in any situation.

I must admit that I have often rebelled against discipline. I thought it would cramp my style or limit my freedom. What I have learned is that discipline enforced by a dictatorial person does cramp everyone’s style and limit freedom. Discipline agreed to by each individual does the opposite. Self discipline allows us to achieve excellence.

Discipline that grows out of a commitment to a common purpose creates a structure, a consistency that helps people to make wise choices. The unwillingness to accept poor behavior is reassuring. Employees see leaders behaving consistently and they are inspired to think and behave in alignment with purpose and values. Extensive work rules are not needed when people are already motivated.

Whether you lead an organization or just yourself, discipline will determine much of your success. Each day examine your thinking, your behavior, and your decisions. Ask: “Does this fit with my purpose? Is this a true reflection of who I am? Does this fit with my organization’s purpose and values?” Learn to say “No” to thoughts and behaviors that do not align with purpose and values. Say “Yes” to thoughts and behaviors that affirm your purpose. Thinking, and then doing the right things consistently will keep you on purpose and lead you toward greatness.

Connect the dots. Apply this information to your workplace, your church or spiritual community. your family, your neighborhood, your athletic team. Is there a common purpose that inspires your passion and commitment? Are there values you live by? Do you value and serve each other in order to achieve your common purpose? How can you create a culture of discipline without becoming a disciplinarian? How can you work with others to create an environment where people are clear and self motivated?

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.

Source by William Frank Diedrich

The Basic Apparatus Used In Pilates

Pilates classes were designed to increase focus, remove stress and tension from the mind and the muscles and also make one’s life better through basic exercise by developing controlled movement from a strong core. Joseph Pilates originally developed his method in 1945 as mat exercises and used several pieces of apparatus to help people with improving one’s inner and outer image by feeling and looking great. Each piece of apparatus has its own set of movements and exercises and focuses on certain aspects of one’s body.

A Pilates studio uses a wide range of apparatus which most are for resistance training which allows one to choose how hard they want to work out according to their fitness level and strength. A spring is used to apply the progressive resistance so the further one stretches the spring the more resistance there will be. The most widely used apparatus in called the Reformer and is probably the most important. Pilates classes will also have apparatus such as the Cadillac or Trapeze Table, the High or Electric Chair, the Wunda Chair, the Baby Chair, the Ladder Barrel, the Spine Corrector or Step Barrel and the small barrel.

All these apparatus come with specifically designed exercises and routines which focus on certain aspects of the body which you want to improve and strengthen. In contemporary Pilates other props are used such as small weighted balls, foam Rollers, rotating disks and resistance bands. As technology improves more and more equipment tends to change but the basic principles set out by Joseph Pilates tend to stay the same. There are 2 different types of Pilates today though, the Classical/ Authentic Pilates which tries not to vary from the original teachings on Joseph Pilates and build their equipment according to his exact specifications. The classical instructors training can also usually be traced back to either Joseph Pilates himself or to one of his protégés. The Modern/ Contemporary Pilates are vary their exercises from lesson to lesson and use most modern-day equipment and exercises from around the world with the basic principles.

So whether you chose Classical or Modern Pilates they are both designed to tone one’s body and mind to work more effectively and efficiently, increasing focus, energy and overall well-being. Each Pilates studio has its own methods, classes and apparatus which the instructors have stocked or sometimes built from the teachings of Joe Pilates. Finding the right exercises and places to go are hard today because in today’s life the choices are endless and there are studios and exercise routines from around the world being offered to us with strange apparatus with names that put a smile on one’s face.

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.

Source by Andrea M. Da Silva

Right To Information Act, 2005

Introduction:

This legislation may be termed as one of the rarest legislations in the Indian Legal History which provides for setting out the practical regime of ‘Right to Information’ for Citizens to secure access to information under the control of public authorities and in order to promote transparency & accountability in the working of every public authority, the constitution of a Central Information Commission and State Information Commissions and for matters connected therewith or incidental thereto.

This Legislation will prove to be a ‘Landmark’, since it is enacted NOT for the people to follow but for the Government to follow.

Through this legislation, the Government has made an attempt to administer itself, be answerable to the people & penalize itself for lacking in providing the required information and regain people’s lost confidence in the bureaucratic system and setup.

Extent and Commencement:

This Act extends to the whole of India except the State of Jammu and Kashmir. This Act of Parliament received the assent of the President of India on the 15th June, 2005.

Some Important Definitions:

1. Information [Section 2(f)]:

Information means any material in any form, including records, documents, memos, e-mails, opinions, advices, press releases, circulars, orders, logbooks, contracts, reports, papers, samples, models, data material held in any electronic form and information relating to any private body which can be accessed by a public authority under any other law for the time being in force.

2. Record [Section 2(i)]:

Record includes-

(a) any document, manuscript and file;

(b) any microfilm, microfiche and facsimile copy of a document;

(c) any reproduction of image or images embodied in such microfilm

(whether enlarged or not)

(d) any other material produced by a computer or any other device.

3. Right to Information [Section 2(j)]:

Right to Information means the right to information accessible under this Act which is held by or under the control of any public authority and includes the right to –

(i) inspection of work, documents, records;

(ii) taking notes, extracts or certified copies of documents or records;

(iii) taking certified samples of material;

(iv) obtaining information in the form of diskettes, floppies, tapes, video cassettes or in any other electronic mode or through printouts where such information is stored in a computer or in any other device.

4. Public Authority [Section 2(h)]:

Public Authority means any authority or body or institution of self- government established or constituted-

(a) by or under the Constitution;

(b) by any other law made by Parliament;

(c) by any other law made by State Legislature;

(d) by notification issued or order made by the appropriate Government,

and includes any-

(i) body owned, controlled or substantially financed;

(ii) non-Government organisation substantially financed, directly or indirectly by funds provided by the appropriate Government;

Exemption from disclosure of information [Section 8]:

Like any other legislation, this Act also provides for exemptions to the Government from disclosure of information regarding information – which would cause a breach of privilege of Parliament or the State Legislature / harm the competitive position of a third party / endanger the life or physical safety of any person / impede the process of investigation or apprehension or prosecution of offenders / weaken confidence of the Foreign Government / Disclose the Records of deliberations of the Council of Ministers, Secretaries and other Officers / relates to personal information which has no relationship to any public activity or interest, or which would cause unwarranted invasion of the privacy of the individual unless the Central Public Information Officer or the State Public Information Officer or the appellate authority, as the case may be, is satisfied that the larger public interest justifies the disclosure of such information / involve infringement of copyright.

IMPACT: To hide or avoid giving the required information demanded, the Officers of the concerned Public Authorities may resort to take advantage of these Exemptions. Hence it may be necessary for the ‘Information Seeker’ to be clear in his mind about the exact interpretation of the provisions and exemptions so that he may not be taken for a ride by the officials and can claim his Right to information rightfully.

Administration of the Act [Section 12]:

A body to be known as the ‘Central Information Commission’ is constituted to exercise the powers conferred on, and to perform the functions assigned to, it under this Act. The Central Information Commission shall consist of- The Chief Information Commissioner and such number of Central Information Commissioners as may be deemed necessary.

Every State Government shall constitute a body to be known as the

(name of the State) Information Commission to exercise the powers conferred on, and to perform the functions assigned to, it under this Act. The State Information Commission shall consist of- The State Chief Information Commissioner and such number of State Information Commissioners as may be deemed necessary.

The Central Information Commission or State Information Commission shall, while inquiring into any matter under this section, have the same powers as are vested in a civil court while trying a suit under the Code of Civil Procedure, 1908.

Every public authority shall designate as many officers as the Central Public Information Officers or State Public Information Officers, as the case may be, in all administrative units or offices under it as may be necessary to provide information to persons requesting for the information under this Act. Every public authority shall designate an officer at each sub-divisional level or other sub-district level as a Central Assistant Public Information Officer or a State Assistant Public Information Officer, as the case may be, to receive the applications for information or appeals under this Act for forwarding the same forthwith to the Central Public Information Officer or the State Public Information Officer or senior officer specified or the Central Information Commission or the State Information Commission, as the case may be.

Timeframes within which the desired information should be made available by the concerned Public Authority:

A person who desires to obtain any information shall make a request in writing or through electronic means in English or Hindi or in the official language of the area in which the application is being made, accompanying such fee as may be prescribed, to-

(a) the Central Public Information Officer or State Public Information Officer, as the case may be, of the concerned public authority;

(b) the Central Assistant Public Information Officer or State Assistant Public Information Officer, as the case may be, specifying the particulars of the information sought by him or her.

An applicant making request for information shall not be required to give any reason for requesting the information or any other personal details except those that may be necessary for contacting him.

On receipt of a request the Central Public Information Officer or State Public Information Officer shall as expeditiously as possible, and in any case within Thirty Days of the receipt of the request, either provide the information on payment of such fee as may be prescribed or reject the request for a reason. If the Central Public Information Officer or State Public Information Officer fails to give decision on the request for information within the said period it shall be deemed to have refused the request. The person making request for the information shall be provided the information free of charge where a public authority fails to comply with the time limits specified.

IMPACT: Making requests for information through electronic means may not be easy practically, since not all the Public Authority offices are fully computerized and may not have computer savvy staff. The urban class who may resort to make request through electronic means may get discouraged. Explanations like, ‘Computer error’, ‘Server down’ may be resorted to, for avoiding furnishing of information.

Penalties for not making available the desired information:

If without any reasonable cause, the concerned Officer refuses to receive an application for information or has not furnished information within the time specified or malafidely denied the request for information or knowingly given incorrect, incomplete or misleading information or destroyed information which was the subject of the request or obstructed in any manner in furnishing the information, a penalty of two hundred and fifty rupees each day till application is received or information is furnished, so however, the total amount of such penalty shall not exceed twenty-five thousand rupees shall be imposed and / or disciplinary action against the concerned Officer may be taken. Provided that the Central Public Information Officer or the State Public Information Officer, as the case may be, shall be given a reasonable opportunity of being heard before any penalty is imposed or disciplinary action is taken against him.

CONCLUSION:

The enactment of the Right to Information Act, 2005 makes a noteworthy attempt to streamline the working of the Public Authorities in respect of providing information to the people. The Authorities will require being technology savvy, alert and need to imbibe in them the not before attitude, of being answerable to the citizens. The Public Authorities will now require tightening their belts so as to serve the people and truly contribute to the Information Technology era. As for the citizens, this Act makes them aware of their one of the Constitutional Rights – Right to Information and gives them the opportunity to exercise it in good faith.

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.

Source by Dr. Anand Wadadekar

How The Simple Lemon Can Heal The Liver & The Body & Benefit Those With Cancer & Hiv / Aids

For years the lemon has sat awkwardly amongst other fruits. As children we knew the lemon tasted bitter, and because of this, we often found ourselves drawn to its peculiar mystique.

In recent years, the lemon has been used to control the spread of the HIV virus, and has been demonstrated in research studies to kill the HIV virus.

Dr Peter Piot of UNAIDS hailed the discovery that the juice of the lemon kills HIV in the test tube, declaring: ” UNAIDS would like to give you (Professor Roger Short and your ‘LemonAIDS’ team) every encouragement to pursue this exciting new lead.”

Keeping the liver healthy is a critical step in the health and recovery of both cancer patients and those with HIV / AIDS.

According to Dr Leo Roy MD, ND [Immune Perspectives], “No disease, especially degenerative diseases including cancer and AIDS, could survive longer than a few weeks in the presence of a healthy liver.”

A recent discovery by those working with HIV / AIDS has found that combining the simple lemon with extra virgin olive oil and blending these together (with the lemon rind and seeds) and a glass and half of spring water, can and does produce amazing results, when drunk on a daily basis.

The lemon and the extra virgin olive oil, when taken together, act as a potent liver and gallbladder flush, detoxifying the liver, lowering biliruben levels, removing heavy metals, increasing the production of bile from the liver, stimulating lymphatic flow, and restoring the pH of your saliva, which in turn helps you to absorb the nutrients from the food you eat.

The liver is truly the master organ of the immune system, producing chemicals to combat viruses (including the HIV virus) and bacteria, supporting phagocytic [immune function], and producing antihistamines to neutralize substances that promote the growth of cancer. When the liver is not functioning properly – and is over-blocked by toxins – the body’s immune system is severely weakened leading to chronic illness. The lemon & extra virgin olive oil drink not only prevents chronic illness, but works to reverse it.

According to Mark Konlee from his paper How to Reverse Immune Dysfunction – “The immune system has two ‘arms’ – the TH1 and TH2 systems. They tend to be connected: when the one is strong, the other is weak, and visa versa. The Lemon / Extra Virgin Olive Oil drink has been reported to balance the two arms of the immune system. This would help in both suppressed immune system and autoimmune conditions (including HIV / AIDS and cancer).”

Restoring pH levels to normal alkaline levels of 7.0 or greater, is of tremendous importance for the cancer patient. Lemons are one of the most alkaline forming foods on the face of the planet, and when consumed on a regular daily basis (especially with the rind and seeds), cause pH levels in the body to rise and become very alkaline, to levels typically above 7.4 or greater, making it difficult for cancer cells to survive because of the amount of oxygen present. The majority of cancer patients have acidic pH levels of below 6.5, meaning that normal cells are not able to respirate or “breathe” properly. This causes cells to mutate and become cancerous. This discovery was made by Nobel Prize winner Dr. Otto Warburg, who discovered that cancer cells only thrive in a low-oxygen state. In this way, the simple lemon can help to fight cancer.

The lemon & extra virgin olive oil drink also helps to lower and restore biliruben levels in those with liver cancer and liver disease. An elevated biliruben level is a key indicator of a damaged liver. Recently a patient of mine with liver cancer, who had a consistently high biliruben level of 36 (disqualifying her from chemotherapy), took for the first time the lemon & extra virgin olive oil drink. She drank her first and only drink on Thursday. Her biliruben levels had been measured 3 days before and were at the usual 36. She was tested on Friday (one day after her first drink) and her biliruben level measured 28, then two days later it was measured, and it was at 22 (to a near normal level)! This ordinarily skeptical woman was gobsmacked!

So the next time you find yourself walking past a lemon tree, consider how the simple lemon can and is beginning to wage the war against two of the world’s most devastating diseases – cancer and HIV / AIDS.

For further information on the Lemon / Extra Virgin Olive Oil Drink and related articles and research on cancer and HIV / AIDS and beating these diseases naturally, go to www.alternative-cancer-care.com

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.

Source by Glen Russell

Chad Waterbury’s 10-10 Transformation Training and Nutritional System

Are you looking for a complete body transformation but you aren’t sure what to do for workout and diet? Do you have 12 weeks to commit yourself to something that will change the way you look forever? If you want to turn that pear shape into a V-shape with 6 pack abs I recommend you check out my experience with Chad Waterbury’s 10/10 Transformation.

The first thing I have to say is that I am a big fan of Chad Waterbury. He puts out excellent workout programs with his state of the art theories on muscular development and recovery. He’s been the new guy on the block for the last couple of years but has been gaining notoriety quickly because his programs do something very important. They produce real and noticeable results!

Before I continue let me give you a quick bio from his website so you know this isn’t another run of the mill trainer:

Chad is a neurophysiologist and author.

His training methods are used by a wide range of athletes, bodybuilders, models, and fitness enthusiast.

Chad is the director of strength and conditioning at Rickson Gracie Int. Jiu Jitsu Center in LA.

Chad is a regular contributor to the T-Muscle bodybuilding website.

Chad has a master’s degree in physiology from the University of Arizona.

Chad’s focus there was on the neurophysiology of human movement and performance. This lead him to make radical changes in the way he trains competitive athletes. His workouts are now shorter and faster, producing superior results in strength, power, and muscular development.

His eBook, the 10/10 Transformation, is a remarkable triumph of new muscle technology put to work. It’s designed to have you gain 10 pounds of muscle and lose 10 pounds of fat in 12 weeks. Your body weight will be exactly the same but you will look completely different by shedding a few inches off of your waist and adding 10 pounds of pure muscle to your physique. If you can shrink the waistline while beefing up the upper body you will be amazed at the difference you can make in your appearance.

The 10/10 Transformation has several elements that appealed to me. As a fitness enthusiast I am always looking for a great routine that will give real visible results. Standard routines and diets are just plain boring. The 10/10 mixes everything up with challenge and change throughout. It includes a daily diet, daily workout routine, supplement regime, and tips for success. It is a very easy program to follow but you must be ready to commit yourself to some grueling workouts. The program divides itself into four separate three week programs. Your body will not be able to fully adapt to this which means you will get steady results for the entire 12 weeks. The first three weeks is fat loss, followed by 3 weeks of muscle gain, 3 more weeks of fat loss, and a final 3 weeks of muscle gain to add the finishing touch to your body.

By focusing exclusively on either fat burn or muscle gain during each 3 week period you can maximize your results, keep your body off guard, and keep your mind fresh without getting bored. During the 3 week body fat phases you will do 3 full body workouts during the week which vary the rest, rep, and the load of the weight. I did those on Monday, Wednesday, and Friday. They only take about 35 minutes but you will be in a full sweat and exhausted at the end. These workouts build muscle and burn fat. You do need to have a bit of conditioning under your belt to tackle these workouts because they will kick your butt. The other two days of the week you do a 20 minute HIIT cardio session. Total time spent in the gym is about 3 hours during the entire week. That’s not much time to drop 5 pounds of fat and get stronger at the same time! During my initial 3 weeks I was a bit loose on the diet having 3-4 cheat meals per week rather than the prescribed 2 (yes you get to eat cheat meals, pizza for me!) At the end of the first 3 weeks I lost 1 inch off of my waist while gaining 2 pounds on the scale. I have found that every inch off my waist equates to 4-5 pounds of fat so I lost about 4 pounds of fat and gained 6 pounds of lean body weight. The difference in my physique was dramatic. You might be thinking that is a lot of mass to gain but I started using creating during that 3 weeks and typically my muscle cells volumize and I gain exactly 6-7 pounds once it is in my system so it was right on target. I lost close to 5 pounds and my muscles had more volume from the creatine.

I went right into the muscle building phase which is a nice change of pace. Waterbury uses something very radical called HFT or High Frequency Training. I trained each muscle about 5 times per week. The weight, reps, sets, and rest periods are changed up each workout so it keeps your body guessing and allows the separate pathways in the muscles time for recovery. I gained a stunning 8 pounds in 3 weeks. I was really sore the first week but got used to it. Part of my success was sticking very close to his diet which recommended a heavy amount of BCAA’s during the entire 3 weeks. High protein, supplemented BCAA’s, and rigorous workouts for 3 weeks put slabs of muscle on quickly. There are no cardio workouts during the 3 weeks because the body needs all of it’s time for rest.

After those 6 weeks I already had a big transformation in my body so the book was already well worth the price. I completed the transformation and can tell you it lives up to its name. The initial 3 week fat burning program is so effective that I have used that segment alone 3 more times during the course of the year when I want to drop 5-6 pounds quickly and gain some muscle.

If you’re looking for something that is extremely effective for fat loss and muscle gain then I highly recommend the 10/10 workout. The diet plan is simple to follow and easy enough for someone that doesn’t have any time to cook or prepare meals. It lays out every detail in this 1 simple book and leaves nothing to chance. The other thing I liked was you will now have 4 routines that you can use at anytime. If you want to lose fat you can pull out one of the two fat burning workouts or on the flip side gain muscle with one of the two 3 week muscle gaining routines.

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.

Source by Rick Porter