With 52,000 more firms due to come under the Senior Managers Regime by 2018, in the new T-C News magazine Simon Mercer, Unicorn ComplianceServe Product Manager, asks ‘What’s your training strategy for compliance?’
“Do not put it under the jurisdiction of Compliance or HR”, Simon argues. “It has to be championed by a Senior Manager and driven from the top down.”
Find out why by downloading the January 2017 edition of T-C News for free from the website at www.t-cnews.co.uk
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)
ABCUL – the leading trade association for credit unions in England, Scotland and Wales – is helping its members improve and demonstrate their skills and professionalism thanks to a partnership with financial services training specialists, Unicorn.
With new innovations and opportunities for credit unions, plus the recent arrival of the FCA’s new Senior Managers Regime and Certification Regime, training and evidencing competency is more important than ever.
Credit unions – member-owned providers of savings, loans and a range of financial services for communities and workplaces – serve more than 1.2 million people in Britain and hold over £1.3 billion in assets, and are regulated by both the Bank of England’s Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA). ABCUL (the Association of British Credit Unions Ltd) has therefore launched a comprehensive and innovative new compliance training solution for members to meet the required regulatory standards.
ABCUL Learning Academy is powered by Unicorn’s award-winning Learning Management System (LMS), populated with an extensive compliance eLearning library, which provides credit unions with the means to reduce risk through relevant practical training designed to encourage the right behaviours in staff and directors.
Rosanna Donovan, ABCUL Head of Member Services, believes ABCUL Academy is already transforming how credit unions meet their training needs. “Over the last decade, British credit union membership has doubled and assets have trebled,” she says, “so our rapidly expanding sector recognises that we need to meet and demonstrate the highest standards of knowledge and compliance to reassure the growing number of consumers who trust us with their money.”
“As credit unions are governed by volunteer directors and many also have volunteers in operational roles, Unicorn’s LMS and content suite is the perfect solution to allow credit unions to train their people in a way that suits their lives, and to track and demonstrate compliance to their members and regulators.”
ABCUL Academy meets the industry demand for ‘snackable’, just-in-time and role-relevant learning delivered online that embeds core knowledge in line with FCA regulation and heightens awareness of the serious consequences of non-compliance.
New diagnostic tools, Apps and mobile learning, with on and offline syncing, video and role-specific scenarios all create impactful, personalised learning pathways within ABCUL Academy. These instantly connect learners with their day-to-day activities and embed the learning required for firms to meet all the FCA’s regulatory demands.
Simon Mercer, Unicorn Product Manager, continues: “The FCA is challenging firms, credit unions included, to prove their staff or volunteers are competent and compliant, so the evidencing is as critical as the training itself. We are delighted ABCUL has partnered with Unicorn for the solution to support its members.
“ABCUL Academy enables the deployment of content, monitoring, reporting and automatically assigning learning from its content catalogue, CPD, creating role-based pathways and sending email reminders to effectively deliver the right learning. For those who may not need to do a whole course but want a refresher or reminder, highly visual summary module PDFs provide a useful referral tool for key messages.”
In 2016 Unicorn’s learning managment system, 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, compiled by the influential Craig Weiss. For more information about Unicorn’s solution for the financial services sector visit www.unicorntraining.com/complianceserve
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.
Helping staff stay on top of their regulatory and ethical responsibilities around such emotive issues as vulnerable customers and financial promotions must remain a priority for the financial services training industry.
The BCCA is a leading trade association for the UK’s alternative lender market, and they have teamed up with Unicorn to offer online compliance training to their members for the first time, through Unicorn’s ComplianceServe training solution.
Last month BCCA CEO, Jason Wassell, revealed their relationships with vulnerable customers are part of “nearly every discussion” he has had with the Financial Conduct Authority (FCA).
This followed the FCA’s challenge to firms to review their approach to consumer vulnerability, with some customers being confronted by a “computer says no” response when they seek assistance and support from firms.
Meanwhile, financial promotions for consumer credit are amongst the issues also under scrutiny from the regulators, with both a high-profile media and political focus on the advertisement of high cost, short- term credit products.
Simon will be on the Unicorn stand at the BCCA conference, speaking to delegates about their approaches to staff learning and development on these and other credit industry topics. He insists when staff lack the knowledge, empathy and ethics to deal with such issues effectively, the consequences go way beyond being purely financial.
“It only takes one bad news story to destroy a firm’s reputation; one customer who has been treated unfairly, one ad that is viewed as exploitative, appearing on the news or held to task by the consumer advice media.
“The regulator will make its own judgments on penalties and sanctions for companies found in breach of its standards, but realistically it can be public condemnation and PR impact that can prove more damaging long-term.
“Having a training approach where such issues are included as part of a firm’s wider ethical business culture, and not treated in isolation as a ‘tick box’ exercise to appease the regulators, can go a long way to avoiding such reputational damage.”
Earlier this year, Unicorn Training joined forces with FSTP to introduce the enhanced, sector-specific compliance learning solution, ComplianceServe, which includes integrated T&C guidance and CPD management.
As two of the UK’s most prominent financial services training providers, this partnership brings a more targeted, streamlined approach to compliance, to help regulated firms embed the genuine cultural and behavioural change needed to deliver better outcomes for customers.
FSTP was recently named ‘Business Partnership of the Year 2015’ by the Debt Resolution Forum (DRF) and Debt Managers Standards Association (DEMSA), while in January Unicorn’s learning and performance platform, SkillsServe, was ranked top LMS for financial services, and fifth overall, in the global Top 50 LMS Report 2015.
Unicorn has been creating L&D and compliance solutions for the UK’s ever-changing financial services sector for over 25 years. FSTP provides first class training and consultancy services across all sectors of the financial services industry.
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.
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