The FCA has, for the first time, published a notification form* for firms to use when notifying the Transaction Monitoring Unit (TMU) of transaction reporting issues. This may help FCA processes however the form is interesting in that it requires quite a lot of information at the point of notification.
Not only does the form ask for details on the length and scale of the issue and how it was identified, it asks:
- What weaknesses there are in the reporting systems and controls of the firm
- What plans are in place to audit or review transaction reporting and the scope of these reviews
- But most notably, ‘Who within the firm has oversight responsibility for transaction reporting’.
Additional responsibilities under SMCR
Under the recently introduced Senior Managers and Certification Regime (SMCR), an individual within a firm must have overall responsibility for reporting. This is therefore a timely reminder for firms to consider how clear their allocation of responsibilities is, and their ongoing supervision within their firms.
More broadly, firms should consider if they have an issue management and escalation process in place. They may also want to consider whether that process will deliver all the information the FCA is requesting and to look at their reporting assurance process and whether independent testing may be warranted.
Read our earlier blog which outlines transaction reporting under the Senior Managers and Certification Regime.
*The link to the form will download.