“Do not underestimate this, it’s horrible!” You can always count on the ladies from FSTP to call a regulatory spade a spade…
But Julia Kirkland and Philippa Grocott from our SME compliance partners have a happy knack of making even the driest regulatory subject matter entertaining and informative.
And they achieved this again as they delivered two sessions on the hot topics in regulation at Unicorn’s Summer Client Forum at the O2 Continental in London.
In a mock interview, Philippa, playing the role of an FCA inspector, and Julia, in the guise of an ill-informed bank CEO, left delegates in no doubt as to the implications not being able to answer questions on their policies, procedures, systems and protocols around three large, topical pieces of regulation – the Senior Managers and Certification regimes, MiFID II and GDPR.
Yet as tongue-in-cheek as this scenario played out, the message was clear – all this is coming in 2018. You have to address it now!
Delegates were talked through the key focus areas to emerge from the FCA Business Plan 2017-18, both cross sector and specific to the specialist industry sectors of wholesale, investment management, pensions and retirement income, retail banking, retail investments and retail lending.
The expert pair then took it in turns to outline the key requirements, challenges and considerations around the Senior Managers and Certification regimes (Accountability 2), MiFID II and GDPR.
Some delegates had already been through Accountability 1, while others are amongst the 52,000 firms who still have that to look forward to in 2018. Some were already working through their MiFID II responsibilities while everybody was trying, or is going to have, to get a handle on the pervasiveness of GDPR and what it means for data collection and handling in their firm.
It was with regards to GDPR that Julia uttered the opening phrase of this blog!
So how much could YOUR senior managers articulate on these areas at the moment? And it’s not just your senior managers and Board members who need to be fully versed in all this either now. FSTP have anecdotes of visiting regulators walking through offices and asking individuals questions on the things that matter too – it really can be anybody at all levels in the spotlight.
Good systems will get you so far, but it is people who will keep you compliant and that is why training should be top of the agenda for the regulation(s) that affect your staff, yup including your senior managers and Board.
It was then over to Simon Mercer, ComplianceServe product manager, to explain how Unicorn were geared to support clients in each of these three regulatory areas, with new content coming online for GDPR and MiFID II later this summer.
Meanwhile updates to Senior Managers and Certification regimes titles is part of Unicorn’s ongoing content maintenance programme and includes updates to the conduct rules for firms impacted by Accountability 2.
Major new functionality to help firms aggregate ‘the need to know’ stuff on the SMR and Certification Regimes are also being introduced to the ComplianceServe platform before the end of 2017.
This includes Senior Management Functions and Prescribed Responsibilities, assigning functions and responsibilities, statements of responsibilities for SMF holders, defining and managing the criteria for competence, tracking individual progress against criteria and lots, lots more.
Regulation was just one item on the Unicorn Client Forum agenda, with employee engagement, cyber resilience, apps and content and LMS features also getting the ‘deep dive’ treatment.
More from the forum will be online tomorrow. Watch this space…
Simon Mercer, Unicorn ComplianceServe Product Manager, and Julia Kirkland, Partner at FSTP, presented a recap on what’s happened so far, looked ahead to what are going to be the hot regulatory topics over the next 12-18 months and answered the biggest question of all, how on Earth are we going to do all this?? Julia even sang a little bit. It was beautiful.
Anyway here are the top five takeaways on compliance training and where we go next…
The Senior Managers Regime and accountability will remain firmly on agenda – last week the FCA fed back on the first tranche of it accountability regulation, which took effect in March, stating that many firms have misunderstood the guidance. In a nutshell, the screw is going to keep turning. With 55,000 more firms due to come under SMR by 2018, Julia’s key message to anyone still grappling with the challenges of SMR was do not put it in compliance or HR! It has to be championed by a Senior Manager and driven from the top down. The good news is the FCA is suggesting there won’t be a ‘big bang’ on the next tranche of SMR and Certification implementation, but as we’ve seen from the first phase a year’s gap is nothing in these terms. Which brings us neatly to…
How are you bench marking people ahead of the Certification Regime? – firms who have already had to adhere to SMR regulation only have until next February – that’s five months – to put a robust certification process in place. In a quick show of hands amongst the delegates in the room, only one firm who had moved over SMR had already got their certification regime running. Under certification you are asking people who weren’t previously approved persons to take on more responsibility, knowledge etc, so how are you benchmarking these people? What competencies and/or qualifications are you using as a baseline? What are the KPIs and the core competencies required for a role? How are you going to issue that individual with a certificate? And remember the Senior Manager has the ultimate responsibility for saying they’ve signed that person off. It’s a big deal.
What’s hot in 2017 and what’s relevant to you – Julia outlined how she and her FSTP colleagues had trawled through the FCA’s annual risk documentation and picked out what they believe to be the 12 biggest areas of interest over the next 12 months. She did threaten to rap at this juncture also…regardless this is the list.
- Conduct risk
- MiFID II
- Transaction reporting
- Certification Regime
- Business strategy and stress testing
BUT (and note the capital letters), even though some will be more relevant to certain businesses than others, the majority are interdependent on each other. They cannot be taken in isolation.
Modernising your learning approach – in the past we have dealt primarily with compliance departments, but this is changing. Within the L&D community learning is being modernised to move from push to pull learning and getting to point where learners have access to resources and tools to pull as well as utilise what’s pushed to them. This includes introducing more elements of microlearning, in bite-sized chunks that is much more informal and on demand in line with the 70: 20: 10 approach to learning. Unicorn’s eCreator authoring tool, built into ComplianceServe, has got a really significant role to play in this. In fact, by Christmas all existing ComplianceServe content will have been re-developed in eCreator, with the smaller chunks of micro learning, to follow. The benefit? By downloading the SkillsServe app learning can take place offline to sync when back online.
There is a brand new generic T&C system now built in to ComplianceServe – we’ve been building and integrating custom T&C systems and functions for clients for a long time but now there’s a generic version for smaller organisations to make use of. This includes:
- T&C Guidance – regulation is only going way way, there will be an ever greater need to evidence competency. Guidance is all about what does T&C mean for an organisation, how do you create a T&C scheme in the first place, what things need do you need to set up a T&C system in ComplianceServe
- Pre-defined forms and workflows
- Offline forms – there is too much to do online for some things. Can be completed, scanned and attached as part of site.
- Pre-built pathways – for e.g. monthly one-to-ones, quarterly action plan and final sign off, can be assigned to both regulated and non-regulated staff (couple of forms different)
The objective is to continue to help firms bring about genuine cultural and behavioural change and more effectively meet their regulatory obligations.
The FCA’s new accountability regime for banks, building societies, credit unions and designated investment firms, which came into force last month, again brought into focus that the need for effective training and robust processes for evidencing competence has never been greater.
This is why ComplianceServe has been enhanced and given a new look and feel, to help firms embed the knowledge and understanding of why this regulation matters and drive the behavioural changes that will lead to better outcomes for customers.
At a glance
- ComplianceServe’s fresh new appearance reflects the latest thinking in user experience.
- It is easier and quicker for employees to find the right learning and create personalised training plans.
- ComplianceServe’s new integrated CPD system automatically tracks completed online learning against a generic scheme based on FCA guidelines. It also allows the recording and tracking of other CPD activities such as face-to-face training, attending conferences or accredited body events, research and reading.
- Over the past six months, with the support of industry partners including FSTP and the British Bankers’ Association (BBA), 11 new eLearning pathways have been added to the ComplianceServe library to help firms respond to regulation.
- The new ComplianceServe also provides on-demand refresher training, using highly visual PDF summaries, to overcome the infamous ‘forgetting curve’.
Simon Mercer, ComplianceServe Product Manager, explains: “The new regulation has not only challenged firms to improve their compliance training practices but also provide robust evidence of their employees’ competency at whatever level they work. Staff must really understand what the regulation means and how to apply it and firms must be able to prove they can.
“The key is delivering personalised, ‘snackable’ chunks of learning on demand from their device of choice, while highlighting the potentially serious consequences of non-compliance for employee and employer. It lets them ‘fail’ in a safe environment where they can learn from the experience.”
The 11 new eLearning pathways immerse learners in realistic scenarios relevant to their job roles, with the opportunity to make decisions and see the consequences in a way that shapes new behaviours. The eLearning features various bite-size learning activities, including teaser videos, case studies and quick summaries, which all contribute to elevated engagement levels, knowledge retention and cultural change.
Simon adds: “We know new knowledge is rapidly lost if it’s not applied quickly following a training intervention and where there is no regular reinforcing activity. Instead of the once a year ‘sheep dip’ approach, ComplianceServe allows firms to push short bites of learning, tests and refreshers to learners on a regular basis to ensure understanding improves over time, behaviours change and culture shifts.”
New ComplianceServe learning pathways include:
• The new Regulatory Framework in Banking
• Conduct Rules
• Senior Managers Regime
• Foreign Tax Compliance Act 2010 (FATCA)
• The basics of CASS (Client Assets Sourcebook)
• Consumer Credit – Handling Arrears
• The Certification Regime
• Three Lines of Defence
• Vulnerable Customers
• Transaction Reporting
In 2016 Unicorn’s learning and performance platform, SkillsServe was ranked the world’s top LMS for the financial sector for the second successive year, and fourth overall across all sectors, in the Top 50 LMSs Report 2016*. For more information about ComplianceServe visit www.unicorntraining.com/complianceserve
* This report is compiled annually by Craig Weiss, named as the most influential person in the world for eLearning for the past two years.
SMR and the Certification Regime have been here almost a month now, but if you think they don’t affect you think again…
For those who believe they are not currently affected by the SMR – don’t get too smug and comfortable.
That was the stark warning issued by financial services training specialists and our partners, FSTP, earlier this month as they reflected on the arrival of the new Senior Managers Regime (SMR) for Banks, Building Societies, Credit unions and Designated Investment Firms and SIMR for Solvency II Insurance firms in their ‘Executive Matters’ eNewsletter.
FSTP expanded on how the regulators are now all about individual responsibility and accountability and everybody across Financial Services needs to prepare. Conduct risk remains top of the regulators’ agenda and dovetails neatly into the new dawn of individual accountability.
The message? It’s on the way to you too, and it looks like it will hit earlier than you think.
You know the drill by now. This new regime is designed to encourage individuals to take greater responsibility for their actions, and for firms to take full responsibility for the fitness and propriety of their staff, underpinned by a new set of Conduct Rules which set out the required standards of behaviour.
It’s never been more important to have the correct systems, training and controls in place to ensure every relevant member of staff conforms to the requirements. Staff must be competent to undertake their roles and understand their individual responsibilities.
As FSTP have stressed, even if you don’t think it impacts you now, it won’t be long before it does.
This is why Unicorn has been busy developing a number of new eLearning titles in partnership with FSTP, which have been added to our ComplianceServe library. And you can check out four short introductory videos, also included with each of the new eLearning titles, to get a flavour of what you need to think about.
Meanwhile, if you want to know more about how ComplianceServe can help you meet your regulatory needs? Click here to visit the ComplianceServe mini-site.
Now here’s those vids…
Introduction To The New Banking Regime
The Certification Regime
Senior Managers Regime
News: ‘Landmark Financial Services Regulation Has Brought Clearer Training Focus’ Says Sector Expert
Unicorn Commercial Director, Mark Jones, believes the industry has seized the opportunity to “look at compliance in the context of cultural transformation” as landmark new Accountability regulation comes into force on Monday (7 March).
Mark insists the training industry’s response has been pivotal in firms preparing for the Accountability Regime, which includes a new Senior Managers Regime, Certification Regime and Code of Conduct, in an overhaul of the regulatory framework by the Financial Conduct Authority (FCA).
As the new regulation around accountability comes into effect, being able to show clear lines of reporting, roles and responsibilities, and producing evidence of competency within the wider context of compliance is critical for regulated firms.
Mark thinks bringing a more targeted and streamlined approach to T&C and compliance for firms has helped them meet the Accountability deadline, while also providing a firm foundation from which to support them in meeting future regulatory deadlines.
He said: “Compliance should be treated as part of, not in isolation to, an individual’s career development plan, and we’ve seen a shift towards that as the Accountability Regime deadline has loomed.
“There continues to be a real demand for ‘snackable’ just-in-time and role relevant learning delivered online that not only embeds the core knowledge in line with the new FCA regulation amongst staff, but also heightens awareness of the implications of staff going off track in encouraging genuine behavioural change.
“New diagnostic tools, Apps and mobile learning, with on and offline syncing, video and role-specific scenarios are all critical elements in creating impactful personalised learning programmes that instantly connect a learner with their day-to-day job role, and embed the learning required for firms to meet all FCA regulatory demands.”
Unicorn’s comprehensive online compliance solution, ComplianceServe, provides firms with the means to reduce risk through relevant practical training designed to encourage the right behaviours.
ComplianceServe enables the deployment of content, monitoring, reporting and automatically assigning learning from its sector-leading content catalogue, CPD, creating role-based pathways and sending email reminders to effectively deliver the right learning through desktop or mobile device.
Meanwhile Unicorn’s partners, leading financial services consulting and training specialists, FSTP, continue to deliver complementary face-to-face training for more senior roles and/or those requiring highly complex and/or specialist knowledge.
Mark added: “The Accountability Regime leaves no hiding place in the FCA’s aims of raising standards and restoring public trust and confidence in the regulated sectors.
“The FCA has already proved it has no problem biting as hard as it barks, as many large fines and sanctions imposed on some of the world’s biggest financial institutions have shown.
“Only effective, robust training strategies will keep firms out of the FCA’s jaws and it is up to us to keep delivering the best solutions to help them.”
For more information about ComplianceServe visit www.unicorntraining.com/complianceserve
Unicorn Training, one of the UK’s longest established and most respected online learning companies, has reported record sales and growth of a third in 2015.
Unicorn sales have exceeded £5.6m (US$8.5m), a 33% rise on 2014, in this calendar year, with more new customers won than ever before as well as the company achieving double-digit growth in recurrent revenue from a loyal customer base.
In 2015 Unicorn’s online learning and performance platform, SkillsServe, was ranked the world’s number one LMS for financial services and fifth overall, and Unicorn will be marking its record year on Stand P14 at the Learning Technologies 2016 conference and exhibition at Olympia on Wednesday 3 and Thursday 4 February.
Peter Phillips, Unicorn co-founder and CEO, said: “Over the past 12 months we have seen sustained growth in demand across all our main activities; platform, bespoke content development and our off-the-shelf compliance library.
“This is particularly true in our core sector, financial services, where demand for high quality regulatory and compliance training, together with increased awareness of the risks of cybercrime, are being driven by rigorous, new UK regulatory standards.”
Unicorn is uniquely positioned to offer turnkey solutions, combining SkillsServe’s sector-leading features with relevant and up-to-date content and outstanding instructional design, backed by long-standing partnerships with such industry bodies as the Chartered Insurance Institute (CII) and the British Bankers Association (BBA).
In addition, having acquired a strategic stake in the world class games studio, Amuzo, at the end of last year, Unicorn is also able to meet the growing demand for mobile just-in-time learning, serious games and on-demand video content.
Peter added: “Looking ahead to 2016, I believe this robust and scalable business model will continue to generate strong growth in our core business.
“Add to this the exciting new opportunities opened up through our partnership with Amuzo and for a company whose purpose for over 25 years has been to provide great learning experiences through the innovative use of technology, these are exciting times.”
For more information about Unicorn Training visit www.unicorntraining.com and to come and see us at Learning Technologies 2016 register for free entry to the Learning Technologies and Learning and Skills 2016 exhibitions and seminars at www.learningtechnologies.co.uk
Being the cheerful sorts we are at Unicorn, we love a bit of good news!
So we were beyond chuffed for our partners, FSTP, when they won the Debt Resolution Forum (DRF) and Debt Managers Standards Association (DEMSA) ‘Business Partnership of the Year Award 2015’ last week!
Consumer Credit is just one area we are working with leading financial services consulting and training specialists FSTP on in bringing a more targeted and streamlined approach to compliance for FCA regulated firms. It’s always fab to have it recognised you’re working with the best of the best ☺
Philippa Grocott, Partner at FSTP, has written a great piece about how, as a partnership, ourselves and FSTP are supporting clients with blended learning and why a blended solution is right for today’s financial service firms.
Through a worked example, she provides a case study of how FSTP helped a Learning and Development Manager from Bank X who required training on the new Individual Accountability Regime in Banking identify what needed to be studied by who, the best format for delivery (face to face or eLearning) and where their budget should be spent.
In the blog Philippa writes: “The blended approach has improved beyond expectations over time, and solutions, using both the classroom and virtual delivery methods, have rightly earned their place and are a must in any annual L&D programme for all organisations.”
It’s a must-read for any FCA regulated firm currently trying to get their head around how to best meet the demands of the new Accountability Framework before the March deadline.
You can check out the full blog here – Supporting Clients with Blended Learning
In December 2014 FSTP won the Thomson Reuters 2014 Best Compliance Consultancy Firm Award, voted for by FSTP clients. Meanwhile in January 2015 our learning and performance platform, SkillsServe, was ranked as the top LMS for the financial services sector, and fifth overall, in the Top 50 LMSs Report 2015. Congratulations again FSTP!
The new Accountability Framework in banking is one of the hottest topics in the FCA regulated world – with less than 6 months until the deadline Unicorn Product Manager, Simon Mercer, explains how Unicorn’s union with FSTP is helping firms rise to the challenge.
When the FCA launched its 2015-16 Business Plan in March, all eyes inevitably looked straight at the deadlines.
‘Senior Manager’s Regime’, ‘MiFID II’, ‘Mortgage Credit Directive’, ‘Certification Regime’, ‘Code of Conduct’ etc are all major changes to the regulatory framework, with even greater consequences and sanctions for non-compliance.
But, as usual, the deadlines are tight, for example, the new accountability framework for individuals in banks, building societies and credit unions comes into force on 7 March 2016 – now less than six months away.
Earlier this year we joined forces with leading financial services consulting and training specialists, FSTP, to bring a more targeted and streamlined approach to compliance for FCA regulated firms.
Now, with FSTP’s help, we’re adding new eLearning titles to our comprehensive compliance training solution, ComplianceServe, to help organisations embed the cultural and behavioural changes demanded within the new framework.
When it comes to the Accountability Framework there are four supporting courses…
- An Introduction to the New Banking Regime
- An Introduction to the New Senior Managers Regime
- The Certification Regime
- The New Code of Conduct
These titles are designed to meet the demand for ‘snackable’ chunks of learning that can be digested little and often, for a more pervasive learning experience that supports the goal of continuous learning.
Learners have to understand and, most importantly, value the possible implications of their actions in terms of how it affects their promotion prospects, earning power, professional reputation and personal pride. This is why compliance should be treated as part of, not in isolation to, an individual’s whole career development plan.
The by-product of this is the benefit it brings to your business, both commercially, and with regards to regulatory compliance when the FCA calls.
All of these new titles are being added to the ComplianceServe library at no additional cost, and like all our compliance titles, we’ll continue to update them in line with ongoing changes in the regulations.
Utilising FSTP’s capabilities in instructor-led training, we’re also able to provide our clients with a truly blended approach – combining our eLearning modules with face-to face-workshops – for the more complex and risk laden roles i.e. Senior Manager and Senior Responsibility function holders.
Want to know more?
Leading financial services consulting and training specialists, FSTP, has joined forces with online learning and performance developers, Unicorn Training, to introduce an enhanced sector-specific compliance learning solution that includes integrated T&C guidance and CPD management.
As two of the UK’s most prominent financial services training providers the new strategic partnership brings a more targeted, streamlined approach to compliance for FCA regulated firms.
Firms and their employees will be able to access industry-leading online compliance training specific to their sector, which is constantly evolving in line with regulatory change and emerging industry challenges.
The partnership builds on the early success of Unicorn’s flagship online regulatory training solution, ComplianceServe, launched last summer to help firms manage their compliance needs through one secure portal that combines a library of high-quality learning assets with advanced content, development and management tools.
In December 2014 FSTP won the Thomson Reuters 2014 Best Compliance Consultancy Firm Award, voted for by FSTP clients. In January 2015 Unicorn’s learning and performance platform, SkillsServe, was ranked as the top LMS for the financial services sector in the Top 50 LMSs Report 2015*.
Mark Jones, Unicorn Commercial Director, said: “With FSTP we are enriching existing content and developing new titles within the ComplianceServe library, including creating sector-specific case studies and scenarios. With integrated T&C and CPD tracking, ComplianceServe will be the market’s broadest, most comprehensive compliance training solution.
“Compliance goes far beyond just training, it’s embedding genuine wider behavioural change. ComplianceServe has been well received and with FSTP’s expertise and experience in consultancy and face-to-face training we will be able to deliver a truly blended and tailored learning experience.
“FSTP are hugely respected within financial services. We have worked with FSTP in a few different ways previously and this is a formalisation of that relationship to bring real compliance benefits for those working in heavily regulated environments where time is precious.”
Philippa Grocott, Partner at FSTP, added: “We recognise the importance of delivering blended learning solutions that deliver at the right level to the right audience, with engaging content which can be accessed at the right time.
“Unicorn is well known throughout the financial services industry for its quality online learning solutions. It makes perfect sense for two award-winning firms to combine capabilities to deliver ComplianceServe, an essential requirement for any financial services firm that wants to stay ahead of the regulatory focus.”
Unicorn has been creating learning and development and compliance solutions for the UK’s ever-changing FS sector for over 25 years. *As well as being ranked top financial services LMS, SkillsServe was also 5th overall in the Top 50 LMSs Report, compiled by global eLearning analyst Craig Weiss.
FSTP provides first class training and consultancy services across all sectors of the financial services industry.
Unicorn has joined forces with respected Jersey-based Sator Regulatory Consulting to enhance Sator’s commitment to providing first class financial industry compliance and regulatory services at global to local level.
The new partnership between financial services online learning specialists Unicorn and Sator now offers a managed service for compliance training through Unicorn’s award-winning ComplianceServe learning and performance platform.
The custom version of ComplianceServe will enable Sator to underline its global market support by ensuring local regulatory and compliance content is up-to-date and relevant, management information for clients is robust and easy to access and learners’ training is completed, tracked and reported.
Sator ComplianceServe was launched in Jersey – a potential market of around 1,000 regulated entities and 15,000 specialist financial services employees – in mid-December. The platform will then be introduced in Guernsey, followed by Gibraltar and the United Arab Emirates.
Helen Hatton, Sator Regulatory Consulting MD, is widely recognised as the prime architect of the modern Jersey regulatory regime. During a successful 10-year tenure as Deputy Director General of the Jersey Financial Services Commission, the island went from blacklisted to achieving one of the world’s best IMF evaluation results.
She said: “The statutory training requirement is actually not met by a one-off conference. First employers are required to test understanding, next the training must include the law, in-house policies and procedures and building awareness through typologies relevant to each employee’s role.
“We researched global platform providers, seeking resilience, experience, quality and a product that was interesting and user friendly. ComplianceServe met these criteria comprehensively and added very attractive additional features. It is outstanding.
“Our target global markets are substantial international financial centres yet relatively small in their own right compared to say the USA or UK. The capital investment necessary to build a first class, feature rich compliance solution is not economic.
ComplianceServe was developed to help firms manage their compliance training needs through one easy-to-use, secure portal, combining a library of high quality learning assets with advanced diagnostic, content creation, and management tools.
A unique feature of ComplianceServe is Unicorn’s new integrated authoring tool, eCreator, a graphically rich, user-friendly, flexible tool for the fast, simple creation, delivery and editing of learning content at the desktop and on mobile.
Sator have recently been shortlisted as a finalist in the category of Consulting Team of the Year for the 2015 Women in Compliance Awards.
Mark Jones, Unicorn Training Commercial Director, added: “I am extremely proud to welcome the Sator team to our Partner Programme.
“Sator brings a level of expertise and professionalism that I see takes compliance training to a new level across the Channel Islands. “With their breadth of local connections, and a reputation to surpass, Sator is the ideal partner to offer a managed service for compliance training.”
Unicorn Training has been creating learning and development and compliance solutions for the UK’s ever-changing financial services for over 25 years.
Unicorn’s experience, industry expertise and award-winning creativity have helped the company grow to be a market leader. In 2013 Unicorn was named ‘Outstanding Learning Organisation’ at the eLearning Awards in its 25th anniversary year.