Supervision – File Reviews, Live Observations and KPIs

During these unprecedented times, the FCA expects firms to ensure that monitoring and supervision of staff is ‘business as usual’.

Adequate resource is a fundamental requirement and top-level commitment is therefore essential. A key indication of this commitment is the quantity and quality of dedicated resources committed.

File Reviews

This is an area in which I see many firms doing well and files are reviewed on a regular basis (by either a supervisor or a central team).

What is the purpose of file reviews?

  • To check the quality of documentation
  • To check the quality of advice
  • To identify development needs in relation to the documentation

Live Observations

Supervisors are normally required to carry out several live observations. The purpose of these is twofold:

  • To check that the adviser is carrying out client activity in line with the company’s standards – maintaining competence.
  • To identify areas that can be developed to improve their effectiveness and the service provided to customers. These needs should be incorporated into individuals’ development plans.

From my experience of working with many different firms, brokers hear and see a lot of the things their advisers say to their clients on a daily basis, as they tend to be in the same office. However, many firms tend to fall down on evidencing observations. This is an area that should form part of the firm’s T&C regime and supervision.

Review of KPIs

KPIs are a good indicator of the way in which the adviser conducts their business. The supervisor will be expected to review the KPIs on a regular basis to ensure that the company’s standards are being met. Where individual KPIs are below standard, this may suggest skill, knowledge or understanding weaknesses, which should be addressed.

If you need any assistance with file checking, live observations and KPIs, please speak to your RWA Business Manager.

About the author

Kirk joined RWA in 2015, having worked in the financial services sector for many years. He started out in both the general insurance and mortgage advice arms of HSBC, before becoming the Compliance Officer at Go Compare and Training & Competence Manager at Optimum Credit. 

At RWA, Kirk is Deputy Head of Compliance. He supports RWA clients by looking after their compliance, training and competence needs and keeping them up to date with regulatory changes. He promotes the achievement of fair customer outcomes and specialises in designing and implementing T&C schemes for firms of all sizes.

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