But since I live in a nation that’s gone football crazy I feel obliged to take a grudging part in the office tradition that is the World Cup sweep.Being from a country that hasn’t qualified for the world’s greatest football tournament since 1958 I’m surprised at how seriously my colleagues take putting their pounds into the pot. From my desk I can see three World Cup wallcharts and someone has been designated ‘chief filler-in’. I hate to think what would happen to the world if a wrong score was entered. I’m sure your firm is taking this practice just as seriously and I commend your diligence as you keep a record of all scores, scorers and free kicks. I suggest you devote similar intensity to your firm’s record-keeping responsibilities. A key strand of the Financial Services Authority’s work is focus on firms’ ability to maintain full and compliant records. Every thematic project focusses on firms’ ability to keep records of the advice and sales process. The results have not been a sweeping victory for the industry as the regulator has found plenty of inadequate practices. For instance, we hear of the FSA visiting firms and asking advisers why they recommended a particular product to a client. Advisers are able to relate their reasons but having this information in their heads is not good enough, it must be on the record. Some firms see putting resources into record-keeping as a cost. It is not. Consider it an investment. For instance, issuing suitability letters to your clients is not required by the Mortgage Conduct of Business rules but you should do so on every occasion, not only for your clients’ benefit but yours too, should a complaint be made in the future. Ensure your record-keeping system is adequate. The long-term benefit will far outweigh any cost. It’s the equivalent of nurturing the grass roots of your football team so you can play a expansive game in the future – a crucial part of being a winning firm. Here endeth the football metaphors. By the way, I got Croatia and Ghana in the sweep. I’m not holding out too much hope. Rob Griffiths is associate director at the Association of Mortgage Intermediaries
Recent examples of FSA enforcement action show we must get used to complying with a justice system where the punishment fits the principle rather than the crime, says Bill Warren
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