Blog: What’s Your eLearning Strategy For Consumer Credit Compliance?
Described as a ‘a once in a generation change in regulation’, the consumer credit market, including payday lending, Crowdfunding and peer-to-peer lending platforms, now comes under FCA regulatory jurisdiction.
So what’s your eLearning strategy for compliance? Unicorn director, Mark Jones, looks at the options.
The new regulations impact on circa 50,000 businesses with existing credit licences, and it is inevitable that not every one of those will have traditionally met the new regulatory standards under the former OFT lighter touch approach.
Treating Customers Fairly (TCF) has always featured at the heart of FCA regulation, and it is no different for the consumer credit market now, with firms now having to follow the Competent Employees Rule.
Embedding a culture of ethical behaviour and compliance reflected instinctively in staff conduct should ensure that compliance is simply a by-product of good practice.
Things to think about
A firm’s training strategy for compliance is integral to this, as is their ability to monitor and evidence an effective Training and Competency (T&C) scheme. One highly effective solution to this is eLearning. But there are so many questions to answer before you get to the point of your online T&C approach hitting the spots that your firm now needs it to.
- What competencies, behaviours, skills and knowledge should each individual member of staff be able to demonstrate specific to their job role?
- How do you know what is good practice?
- Is your firm delivering learning on the correct core compliance topics?
- What processes does your firm have, or now need, to be able to evidence ongoing competence to the new regulators?
- How does your firm work with individuals to ensure whatever their background and prior skills/knowledge they are competent to the regulated standard?
- How do you minimise risk and maximise best practice in the workplace?
All in the evidence
There is no escaping the fact that evidencing and proof of competence will be critical, both in terms of individuals in a firm and across the business in general.
Accordingly regular performance reviews and staff appraisals will, at least in part, take on a more structured approach. But the danger here is that compliance returns to being the sort of ‘tick box’ exercise the industry has spent the years following the financial crisis trying to eradicate.
The FCA itself acknowledges that “this is a once in a generation change in regulation and therefore not all the new requirements will come into effect immediately.”
And that is the real key – embedding a year-round change of culture within your business by ensuring staff stay up-to-date with what is going on in the industry.
It can’t be instant, it can’t be ticking boxes followed by a ‘Phew we’ve done that now, NEXT!’ It has to come through a real understanding of why and how being competent can positively impact on personal, professional and business development. It is a slow burner, but firms should be starting to act now.
What’s your approach?
To bring about required changes in behaviours and mentality, a firm’s training strategy should include engaging content, practical examples and case studies showing how the learning can be applied in real life situations. eLearning provides an ideal format for this.
Meanwhile with learning and performance platforms now providing more simple, effective and robust means of tailoring, recording and evidencing T&C learning – both for individuals and groups of staff within a business – the stress of maintaining up-to-date content and tracking and evidencing performance is removed.
Just as the RDR had financial advice firms chewing their fingernails over attaining and maintaining RDR compliance, so the new consumer credit market regulations will inevitably invoke a nervousness amongst credit firms. It shouldn’t.
*To find out how you can deliver an effective online solution to support your FCA compliant T&C scheme, click here