Maybe the radar got a bit lower, but some things are very clear

It seems the insatiable energy of the Regulator to poke its nose into every microcosm of what we do has no end, such is the need to justify their existence.

For sure we don’t know if it’s true or simply speculation, but the FCA would appear to be looking at smaller brokers with apparently a greater level of enthusiasm than previously perceived, and in no designated geographic areas 

Should this mean anything? We can’t see why if what you believe you are doing correctly is in the best interests of the Client first and foremost. 

You may feel the urgent need to employ an external compliance adviser, if you’re not sure all is as it should be, to get you ship shape. 

But before you do that, you need to know a few things which often get forgotten by the clever spin supplied by these companies:

Compliance Advisers are not regulated by the FCA and ever have beenThey are not regulated by the CII There are no exams in compliance for which any person can apply CII letters  

What therefore does that mean for your company shelling out for this advice?

Technically you are paying for an opinion at best which is often supported by written and verbal diarrhoea at worstThe Compliance  Adviser will not save your bacon, because In the final analysis you’re on your own Any suggestion that in the event of an Arrow Visit you will be secure, protected by the support of the Compliance Adviser is pure baloneyIf you don’t have a Letter of Engagement get one urgentlyOnce you have secured a Letter of Engagement before you sign it, make sure it has been checked by a solicitor.Understand that when you employ a Compliance Opinion Giver, you are taking on a commercial agreement where duff advice will only be sorted out by the Courts of the land. The Regulator will have nothing to do with it, nor will the CII unless their member has acted against the Code of Ethics, which you will be unsurprised to hear you could drive a coach and horses through blindfolded

No, we have not had an Arrow Visit nor do we feel we can expect one, but we have come to the conclusion that to employ an entity commonly referred to as a compliance adviser, is possibly the biggest waste of money we entertained after once having been a member of BIBA   

Yes we had issues with a compliance company we contracted, which we went into without our eyes being open sufficiently and feel that you fellow contemporaries need to be fully aware of what you could be getting into. Hence repeating the deep concerns we have that Compliance Opinion givers have no more official recognition than my left foot and should come with a massive warning notice

Of course it’s your money to spend as you wish, but in truth you would be better keeping it in your bank rather than forking out to those who pretend to know more than you do, when in reality they have less than a clue