We hope that all our readers are well and that firms are operating efficiently in the current pandemic. In our last newsletter we summarized the issues that firms should be considering during the COVID-19 pandemic with the move for most employees to working from home. As a reminder, we have provided the key considerations for firms below:
- Firms should continue to comply with relevant regulations
- Governing bodies should continue to meet and work effectively
- Senior Managers may find that the reasonable steps (for example management information, reporting, meetings) they usually take for their areas of responsibility may need to be enhanced or adapted during this crisis. Records should be maintained of key decisions made, actions taken and any deviation from the usual control environment
- BCPs should be up to date, tested and fit for purpose
- Operational resilience and cybersecurity controls should be robust
- Good client services should be maintained
- Financial resilience and capital adequacy should be closely monitored
- Telephone calls should be recorded where required
- Market abuse should be monitored
- Be aware of the changes in short selling regulations
- Data should be submitted as usual to the Financial Conduct Authority (FCA), however there have been some extensions granted
- The 12-week rule which allows firms to arrange cover for a senior manager without being approved has been extended to 36 weeks
- Full records should made of any problems, issues, remediation action taken or changes to the normal governance and control arrangements, daily if necessary
- Where appropriate, issues should be notified to the FCA
If you need any extra help or advice during this difficult time, please do not hesitate to contact your normal client relationship manager or Ian Manson.
