Policy Statement 08/9 which was published by the FSA last autumn requires mortgage and general insurance Intermediaries to consider their approach to where MiFID firms have already had to strengthen their internal policies since November 2007.
“Organisational systems and controls – extending the common platform” is the policy statement title and has the deadline for implementation by non MiFID firms by the end of April 2009.
The FSA recognised in its consultation that although there is no requirement to use compliance consultancy firms, there is a likelihood that many firms would get additional support from this sector.
The Telos communication campaign includes press articles, on and off-line advertising and information mailings to its intermediary database.
Stephen Atkins, compliance director at Telos Compliance, says: “If asked by the FSA [at your next enhanced strategy FSA meeting] to describe your compliance, internal audit, risk and outsourcing audit processes would you be able to do this? Are they robust and sufficiently independent of conflicts of interest? This is what PS08/9 requires you to do by April 09.”