Despite the current difficult and constantly changing circumstances, regulators are even busier than normal, conducting meetings on both Coronavirus related matters and continuing with the usual regulatory checks. Therefore, it is vital that firms keep on top of the latest FCA thinking, as information and guidance is constantly being updated.
Visits are being carried out in person, where possible, however, some meetings are being conducted remotely, meaning thorough preparation is more important than ever.
If not fully prepared for, meetings held in this unfamiliar setting could increase the chances of raising regulatory concerns through, amongst other things, staff mis-speaking, providing conflicting answers or not being able to evidence their statements.
Many of us will be familiar with video conferencing software by now but it can still be extremely useful to hold virtual practise interviews. This can allow staff to prepare for difficult questions and see how their answers come across but also to ensure that they are following formal video conferencing etiquette.
While practising virtually, it can be useful to record meetings to share and review answers for improvement. However, the actual regulatory meeting must not be recorded without gaining permission in advance and it is usually best not to do this as it can come across as defensive. It is, however, perfectly reasonable to have a note-taker or observer, although it is courteous to notify of this too, whether on or off screen.
For the meeting itself, it is good practice to check that everything is set-up correctly well in advance, including testing audio/visual quality and Internet connection within the selected video-conferencing software.
Also, remember, when talking virtually it can be easy to interrupt each other. So, it is important to allow breaks in conversation to ensure everyone is given the opportunity to speak. This is generally good etiquette but is also particularly important in allowing the regulator to be able to assess the strengths of junior team members, which they are increasingly focused on to get a more rounded picture of a firm’s competency, control, and culture from the ground up.
Another point to be aware of, with remote meetings, is that it can be far easier to get distracted. Staff should be sure to stay aware and show interest in what is being said, ensuring eye contact is made with the camera instead of looking over the monitor or getting too focused on the people on the screen.
Particularly relevant, if conducting a meeting from home, is the importance of making sure to set up in an environment free from disruption and background noise and with an appropriate background.
Aside from considering the virtual nature of the meeting, the usual preparations are still vital. The materials provided by the regulator, prior to the meeting, should be read and possible relevant questions thought through and discussed. It is important to emphasise however, the need to ensure staff have, in addition, read up on the latest related information, as these materials are often sent out months in advance and can be out of date by the time the interviews are carried out.
Ultimately, whether conducted virtually or in person, the questions asked will likely be the same and include some closed and some open queries e.g. ‘what are the greatest risks to the firm?’. Staff should endeavour to be honest and open with their answers and be clear about mitigations and compensating controls.
Varied examples for different scenarios can be useful and should be prepared ahead of time. All staff members should be clear on the details of each chosen scenario as regulators do cross check, with similar questions often repeated for different staff interviews to review how the team works as a whole.
Once the meeting process is complete, if any significant weaknesses have been identified it is advisable to examine ways to address these before any further formal meetings or actions from the regulator.
For help preparing staff, courses covering topics such as video conferencing etiquette and regulatory compliance are available on the Aviva Development Zone and as always, if you need any further advice, please speak to your Regional Business Manager.