Investment Firms

If you would like to read this newsletter offline click here for a PDF download. Note: You will need Adobe Reader to view this document.

1. FSA conclude that TCF is a ‘cultural issue’
2. Always check your letters before issue
3. How secure is your retail customer data?
4. FSA comment on using Platforms, Fund Supermarkets and Wraps
5. FSA produce tools for financial advisers
6. Retail distribution review – FSA release discussion paper
7. FSA ‘Special Investigations’
8. Financial Action Task Force (FATF) Report / New EU Law
9. MiFID action & confirmation of status
10. Client Classification Changes
11. Reforming conduct of business regulation – ‘COB’ will become ‘NEWCOB’
12. Supervisor Training – One space still available
13. Disclosure documents – an update
14. Unique Tax Planning Solutions
15. Don’t fall into the ‘Fast Track Mortgage’ hole
16. FSA finds poor practice within sub-prime market
17. FSA produce ‘Mortgage Factsheet’
18. FSA sets out principles based future for general insurance regulation

Ladies & Gentlemen

Please find enclosed the latest compliance and industry news.

As usual, sit back and enjoy!

Kind Regards

ateb consultants

Which article applies to me?
Please use the following table to decide which article applies to you, if any:

	1	2	3	4	5	6	7	8	9	10	11	12	13	14	15	16	17
Directors/Partners
Compliance / A&O Function
Money Laundering Officer
Advisers & Trainees
T&C Supervisor
Pensions Transfer Specialist
Back Office
Mortgage Related (M)															M	M	M

1. FSA conclude that TCF is a ‘cultural issue’

The FSA are of the opinion that TCF is a cultural issue.

They recently published 'Treating customers fairly – culture' and 'Treating customers fairly - a guide to management information'.

The culture paper contains the culture frameworks which they have developed for supervisors to use when assessing the risk a firm's culture presents to treating customers fairly. The frameworks are based on factors or ‘drivers’ which they believe have a significant influence on behaviours in firms.

The management information paper has been produced to assist firms as they consider how to meet the March 2008 deadline (i.e. have appropriate management information or measures in place to test whether they are treating their customers fairly). The FSA have included some examples of good and poor practice on MI in this publication.

The FSA have stated that where they are satisfied that a firm has robust systems and controls and the senior management are reviewing and using reliable MI which demonstrates that they are treating their customers fairly, they will significantly reduce the level of testing they (the FSA) carry out on the firm’s culture regarding treating customers fairly.

Ateb view:

We think they may have hit the proverbial nail on the head with this one!

Action required by you:

ATEB have just updated its TCF review document for use by firms and will look to discuss the content of these documents with firms over coming months. More information is available at: http://www.fsa.gov.uk/Pages/Doing/Regulated/tcf/index.shtml

Return to Features List or Contact Us

2. Always check your letters before issue

A firm received an unfortunate complaint recently following an administration error.

The background behind this complaint involved a client who been made redundant. She had examined her insurance demands and needs statement which indicated that she was covered for redundancy. This however was a clerical error, the demands and needs statement had been issued based on a template and the firm had omitted to delete reference to redundancy.

As part of the complaint investigation we could not rule out the possibility that the adviser has mistakenly believed that the PHI policy did indeed cover redundancy. When we examined the fact find we found that the relevant section had been completed incorrectly and so consequently the written evidence was inconclusive.

Based on the advisers experience and statement the firm are likely to defend this case, however the outcome is debateable.

Needless to say this episode of events has cost the firm time and money and frustratingly it could have been avoided. The firm has now amended its procedures to ensure that this situation does not reoccur.

Ateb view:

This was an easy mistake to make, however a correctly completed fact find (detailed file notes) would have eased matters considerably!

Action required by you:

Have a check in place before issuing letters to clients, particularly where you use templates and as always take care to gather and record know your customer carefully.

Return to Features List or Contact Us

3. How secure is your retail customer data?

The FSA have commenced a review looking at the treatment of retail customer data. The review, which will look in detail at about 40 firms of different sizes across the financial services sector, will focus on the methods firms use to prevent the loss or theft of retail customer data by employees and third party service providers. The FSA plan to cover the following subjects as part of their review:

• Policies and procedures relating to the security of retail customer data
• Senior management involvement in ensuring the security of retail customer data
• Whether firms are assessing the risk of retail customer data compromise and putting in place sensible and proportionate measures to mitigate the risk
• Controls over retail customer data held in electronic and manual systems
• Controls over the disposal of unwanted retail customer data in electronic and manual systems
• The access to and use of retail customer data by third parties used by your firm such as outsourced call centres, administrators and marketing agents.

Firms are asked to supply information in preparation of the FSA visit which includes amongst other items, a request for risk assessments conducted or internal reports covering retail customer data security in the last two years.

Ateb view:

We are not surprised by this move, certainly with the amount of identify fraud and related crime ongoing at present.

Action required by you:

As smaller firms will have only basic procedures in place to deal with securing customer data, maybe this is an opportunity to review things.

Return to Features List or Contact Us

4. FSA comment on using Platforms, Fund Supermarkets and Wraps

The FSA have already confirmed that using platforms can improve administration and, through this, the services firms can offer clients. However they have issued a word of caution; firms need to make sure that it does not simply increase complexity and costs to clients without giving them new services they value in return.

The FSA are particularly worried about the following areas of potential abuse:

1. the transfer of assets onto platforms where there is no benefit for the customer
2. the way in which platform providers incentivise intermediaries
3. the potential for unauthorised transactions by firms that do not have permission to manage investments
4. the potential for non-transparency in charging structures and the (lack of) disclosure

Firms would be wise to look closely at the FSA discussion paper. Chapters 4 and 5 show case studies that illustrate what the FSA considers to be good practice. Chapter 6 gives practical examples of the way in which the use of platforms can be used allowing firms to maintain their true independence.

Ateb view:

The market has raced ahead of the rule makers here. Platforms have been around for years, so thankfully the FSA have eventually managed to respond and offer some input. They are now keen to facilitate debate and idea sharing between firms about what platforms may and may not be able to offer consumers in the future.

Action required by you:

Firms may be in the process of developing new service propositions as part of TCF. Choice of platform will be central to this decision. We suggest firms start by reading the fact sheet and discuss any gaps with ATEB. http://www.fsa.gov.uk/pages/Doing/small_firms/advisers/pdf/factsheet_wraps.pdf Through their discussion paper the FSA are interested to receive ideas about how best to develop the use of platforms.  Further information can be found at: http://www.fsa.gov.uk/pubs/discussion/dp07_02.pdf

Return to Features List or Contact Us

5. FSA produce tools for financial advisers

The FSA have produced some prompts and tools to help firms in the following areas:

• Know your customer information
  Assessing your customer's needs involves gathering and recording all relevant factual information together with their aims, financial aspirations and views on the degree of risk they are prepared to accept when it comes to investing to achieve these.

• Communication with clients
  This section contains tools designed to help firms in preparing suitability letters for customers. They are not prescriptive and how you choose to use them may depend on your firm's size and business model. The aim is to prompt firms to give more thought to what should (and should not) be contained in these documents and to improve their quality.

• Management information
  Collecting information and statistics about how your firm is operating (management information). The FSA have developed a range of tools to help you identify the type of MI that can be gathered and how it can benefit your firm. The "toolkit" is made up of both informative tools such as a factsheet and our "guide to management information" and practical tools such as prompts for completing a review of a customer's file and examples of Key Performance Indicators.

Ateb view:

There is nothing new here. However it’s good that the FSA have started to produce more practical assistance. Most firms will find that they are already following the guidance or similar, and it doesn’t harm to have this reinforced.

Action required by you:

More information is available at: http://www.fsa.gov.uk/pages/Doing/small_firms/advisers/tool/index.shtml

Return to Features List or Contact Us

6. Retail distribution review – FSA release discussion paper

This Discussion Paper (DP) represents ideas from the market and consumer representatives and follows six months work to address the root causes of persistent problems in the retail investment market.

The ideas seek to improve the current standards of professionalism, find more cost-effective ways of making advice available to a wider range of consumers and improve consumer understanding of what they are getting for their money. To achieve this, the key proposal is that the regulated investment advice market could be divided into two parts giving choices to firms and greater clarity to the consumer. These could be summarised as:

Professional financial planning and advisory services
This service would be offered by two types of adviser. The most highly qualified could call themselves 'independent'. The alternative would involve advisers working on a commission basis, but if they did they would not be able to call themselves independent. The minimum qualifications are likely to be at least equivalent to the old “Advanced Financial Planning Certificate”.

Primary advice
A “new” type of advice for consumers who may not be able to afford, or may not require, professional financial planning.

Ateb view:

The FSA’s work so far indicates that the time is right for this type of review and there is a high degree of willingness to change across the entire market. They want as much participation as possible, particularly from smaller firms and consumer groups and so there will be several events during the next six months providing an opportunity to discuss the main issues and to share views.

Action required by you:

This is a major change and we strongly recommend that all firms respond. During the DP's six month consultation period, which ends on 31 December 2007, the FSA will be actively seeking the views of industry, consumers, professional and trade bodies. As well as undertaking further research on the impact of the ideas in the DP. The FSA aims to publish a feedback statement in Q2 2008. To view the paper click on the following link: http://www.fsa.gov.uk/pages/Doing/small_firms/advisers/rdr/index.shtml

Return to Features List or Contact Us

7. FSA ‘Special Investigations’

Recently one of our clients was subject to very close scrutiny by the FSA.  The reason for this was that they had been selling a product outside of the ‘mainstream’ products.  This was a series of bonds by ‘KeyData’. The FSA were at pains to say that they were not investigating the product, only how it was being advised. 

This product is unique on the market as it invests in whole of life policies using an “actuarial probability model” (sounds like some sort of technology on Red Dwarf!).  Initially the FSA asked for documents associated with the sales over the telephone and then later decided to visit. This visit consisted of one inspector examining client files whilst another interviewed the principal (who had advised on these) and an adviser who had sold a fair number of them.  They were questioned very deeply not only about the advice and sales process (particularly the suitability letter) but also their technical understanding which they obviously expected to be very detailed.

Overall, the IFA firm concerned came through the visit satisfactorily with some minor comments.

However, this particular FSA “themed” visit enabled us to see even further into the FSA psyche and understand where they are coming from and what they expect from IFA’s and brokers.  These are:

• They expect advisers to have a very deep understanding of the technical aspects of the products they are advising
• They expect the adviser to go into some depth with the client to try to get them to understand how the product being advised works and achieves its promised outcomes
• If a non mainstream product is advised they expect a very specific suitability letter communicating technical information clearly and linking to specific benefits.
• They expect to see an attempt at comparing with similar products
• They expect the broad market for the product to be clearly identified by the advising firm (in line with TCF Outcome 2)

Ateb view:

The same firm had passed a TCF visit recently – so just because you have had a visit it does not mean the FSA will ignore you. Broadly, they know what business you are selling and to whom !!!

Action required by you:

If this is an area that you are involved in, ask ATEB for advice whilst we are on our rounds.

Return to Features List or Contact Us

8. Financial Action Task Force (FATF) Report / New EU Law

The Financial Action Task Force (FATF) has completed an assessment (basically they, together with the national audit office, audit the work of the FSA) of the UK’s implementation of anti-money laundering and counter-terrorist financing standards.

Whilst the supervisory system was found to be comprehensive for the larger firms, the FATF felt that FSA supervision of small firms requires enhancement.

The UK AML regime will, however, undergo significant change once the new (yes more!!) Money Laundering Regulations 2007 are finalised, and when they are implemented on 15 December 2007. These Regulations implement the EU Third Money Laundering Directive, which in turn more fully incorporates FATF's Recommendations into EU law.

Ateb view:

Enhanced supervision of small firms was an interesting finding in view of the fact that last year anti-money laundering regulations moved to a risk based approach (which some might interpret as being more relaxed). Maybe we will see some changes here – possibly some FSA themed visits to analyse individual approaches to anti money laundering or greater prescription for the product providers?

Action required by you:

Continue to maintain high standards in this area. ATEB will update its website procedures in December to cater for the EU Third Money Laundering Directive and FATF recommendations.

Return to Features List or Contact Us

9. MiFID action & confirmation of status

Please note: This article is directed only at investment related activity. Mortgage and General Insurance mediation are outside of MiFID.

The Markets in Financial Instruments Directive (MiFID) comes into effect on 1 November 2007, when it will replace the existing Investment Services Directive (ISD).

IFA (and Professional) firms meeting the qualifying conditions for ‘exemption’ on 1 November 2007 will be deemed to be exempt firms (or “non-MiFID” firms) and will be ‘automatically opted out’ of MiFID’s scope.

ATEB will issue separate guidance on what constitutes exemption, however we envisage that most IFAs will be able to make use of the MiFID qualifying conditions for exemption.

Firms that cannot use the exemption will be “MiFID scope” firms and are likely to have greater administrative and or capital resource requirements imposed.

Ateb view:

None - for information only

Action required by you:

Firms should make an assessment of their individual circumstances using a proforma produced by ATEB.

Return to Features List or Contact Us

10. Client Classification Changes

This article is just for investment firms and particularly those who have re-classified some of their existing clients under current COB rules. The changes are likely to impact all investment firms regardless of whether they become a “MiFID” or “Non-MiFID” (i.e. most IFA firms) from 1st November 2007.

MiFID categories are broadly similar but not identical to current COB categories.  This is how the categories broadly translate:

Current COB category	New MiFID category
Private customer	Retail client
Intermediate customer	Professional client
Market counterparty	Eligible counterparty
*Re-classification
Private customer to ‘Expert’ Private customer	Retail client to ‘Elective’ Professional client

*The FSA are still consulting on some of the practicalities, particularly in relation to re-classifying clients (see CP07/9 Chapter 15).

Introduction of the new categories will be as follows:

1. Grandfathering of categories in the scope of permission so that firms don’t have to apply for variation of permission (VOP) unless they want to change client classification categories.
   
2. Transitional period: running between 1 November 2007 and 30 June 2008, to allow the actual differences to bed in.  During this period firms can use the existing criteria for classifying clients.

We will issue further information will follow after the FSA have finalised their proposals.

Ateb view:

None - for information only

Action required by you:

Check your scope of permission to make sure that the categories you currently have permission for will be sufficient for the ongoing needs of your business.  If you need to make any changes, for example add a customer type, you will need to submit a variation of permission by 1 January 2008. Review your client bank to make sure that it is clearly segregated between private clients, intermediate clients and any re-classified clients. During the transitional period, be prepared to review those clients that have been re-classified, to ensure that they continue to map across as shown above. The outcome of this exercise will depend on the outcome of the consultation.

Return to Features List or Contact Us

11. Reforming conduct of business regulation – ‘COB’ will become ‘NEWCOB’

The FSA have released “PS07/6: Reforming Conduct of Business Regulation” which largely provides feedback on the consultations for reforming conduct of business and financial promotion.

The new rule book, which will come into force on the 1st November, has been reduced in size by over half. It is shorter than the existing COB but it still runs to over 200 pages!!

The new rules are effective from 1 November 2007 and there is no transitional period.

Although many detailed rules have gone, there are additional rules about ‘know your customer’. The new rules include the specific requirement to record income and outgoings, risk profiles, assets and liabilities.

Ateb view:

For the purists there are a number of changes. In reality though, firms will see small change from 1st November. Those firms adopting good practices today under COB will adapt well under NEWCOB.

Action required by you:

None - We will provide more information nearer the time. More information can be found at: http://www.fsa.gov.uk/pages/Library/Policy/Policy/2007/07_06.shtml

Return to Features List or Contact Us

12. Supervisor Training – One space still available

Content:

• Overview of general T&C requirements on regulated firms
• Setting customer facing sales process standards
• Consistent and accurate assessment skills
• Theory of coaching and training
• Training Needs Analysis completion
• Constructing SMARTA development plans
• Structuring one to ones
• Monitoring performance

Who should attend?

• Qualified supervisors wishing to top up existing supervisory knowledge
• Newly appointed supervisors
• Supervisors who had previously been classified as ‘self supervising’ (under PIA)

Timings:

10.00 am until 4.00 pm

Location:

Newcastle upon Tyne

Cost: £175 plus vat per person

Ateb view:

Although we often quote the regulatory requirements, don’t forget that quality supervisor training will certainly have a positive impact on your business.

Action required by you:

Please let us know by email or telephone using the contact details in this newsletter.

Return to Features List or Contact Us

13. Disclosure documents – an update

In May this year, the FSA announced that they were proposing to move the initial disclosure document (IDD) and the Menu (IFA firms only) from rules to guidance in November.

However, disclosure rules mean you will STILL have to provide more or less the same information to your customers about the firm's status, the nature of advice, how the adviser is paid and commission disclosure (IFA firms only) from 1st November 2007.

In reality, from November you will have the choice of:

• developing your own material giving VERY CAREFUL consideration to the detailed directive requirements or
• continuing to give clients the menu and IDD, which will allow you to satisfy a number of directive requirements, although you won't have to provide it in the precisely defined format of the current documents.

The FSA will introduce a replacement in 2008 should their research show that it is necessary.

Ateb view:

At present the simplest and most cost effective compliant solution is to broadly use the documents that are in circulation at present. We will watch this space with interpretation.

Action required by you:

Very simple – PLEASE DO NOT throw away your documents just yet!!

Return to Features List or Contact Us

14. Unique Tax Planning Solutions

The following article and content has been supplied by SFM Legal Services, a niche law firm specialising in taxation and property law, based in Team Valley, Gateshead. They specialise in all types of tax planning. In addition, the firm offers advice in relation to protection of assets from long term care fees. We thought you might be interested in a couple of the schemes on offer:

1) Inheritance Tax (IHT) Scheme

Current Situation of IHT: Since the Finance Act became Law on 19th July 2006, effective trust planning for IHT purposes has become severely restricted. Assets above the nil rate band (currently £300K) that are placed into Trust are subject to punitive charges both at inception (20%) and at 10 year intervals (6%) the latter also applies when assets leave a Trust.

There are exceptions to the above such as Absolute/Bare Trusts, Trusts for disabled people and indeed the ‘seven year PET rule’ and the ‘two year rule’ for qualifying Aim Shares still apply, however the inflexibility of these schemes make them unworkable in the majority of cases.

The Solution could be “The SFM Inheritance Tax (IHT) Scheme”. The scheme is not available anywhere else and provides the following key benefits:

• It eradicates the inheritance tax liability immediately thus there is no reliance on the ‘seven year PET rule’ or the ‘two year rule’ for qualifying Aim Shares
• The structure is not a Trust and thus circumvents the inception & 10 year charge.
• The client retains control of their assets.
• The client can invest in a wide range of assets.
• Cash, Shares, Residential & Commercial Property can be placed into the scheme.
• The client can take regular or ad hoc withdrawals.
• Offshore jurisdiction allows 100% investor protection and 100% confidentiality.
• Uncomplicated structure that clients can understand.

2) Asset Protection Trust for Residential Care

Current Situation of Residential Care: In summary the current way in which the English means test works is that if a person’s assets are in excess of £21,500 they will not be entitled to any financial assistance from their Local Authority if they require residential care. The majority of people who own their home will be ‘Means Tested’ to provide one hundred percent of care fees if indeed long term care became an issue. Please note that the transference of assets into another’s name is classed as ‘Deliberate Deprivation’ and thus illegal.

The Solution could be “The SFM Asset Protection Trust” The scheme allows clients to place their property and savings into a protective wrapper and provides the following key benefits:

• Assets within the Trust cannot be means tested by the Local Authority.
• Assets remain safe to pass to children/beneficiaries via a Will
• Clients retain full control of assets
• Clients can make future increments to the Trust
• Clients can have full access to Trust assets at anytime
• Prevents sideways disinheritance

Ateb view:

None - for information only

Action required by you:

If you would like further information ,on these unique schemes feel free to contact Chris Booth on Direct Dial 0191 4958906 or Email: cbooth@sfmfinancial.co.uk

Return to Features List or Contact Us

15. Don’t fall into the ‘Fast Track Mortgage’ hole

Fast-track mortgages are a type of self-certification mortgage. Neither requires proof of income but the difference with fast-track mortgages is that lenders reserve the right to ask for proof.

It is highly probable that a number of lenders under pressure to make sales are encouraging brokers to abuse the FSA rules in this area.

We must therefore remind firms that ‘application fraud’ occurs when incorrect or misleading information is knowingly submitted within a mortgage application. This would include exaggerating income to qualify for a larger advance.

Whereas the rules do not specifically state in so many words that you must obtain verification hard copy evidence we are puzzled as to how else firms can have “reasonable grounds to conclude that the recommendation is the most suitable”. 

We accept that many firms will see specific verification as an extra chore that potentially defeats the purpose of fast track or self certification. However, given the cavalier approach of many lenders we would urge firms to consider very carefully how their file record supports their recommendation.

To reinforce this view the FSA have repeatedly stated on visits to firms and via their website that a “plausibility of income check” is best practice and where a customer has income from various sources including PAYE and wishes to self-certify their income, the firm verifies the customer's main income.

After all, it only takes 5 minutes to ask for copies of pay slips, P60s, bank statements or write to an accountant or simply write down some expenditure.

Ateb view:

Lenders use the “Teflon Method” to communicate their guidance; this means that when there is a problem “nothing sticks” and they know the responsibility falls back to the BROKER.

Action required by you:

Take care and a little extra time to ensure that you back up any fast track or self certification mortgage with good quality documented evidence and by all means discuss this with ATEB on our rounds.

Return to Features List or Contact Us

16. FSA finds poor practice within sub-prime market

The FSA are very concerned that consumers in the sub-prime market are not being properly assessed and advised. The sub-prime market in the USA is imploding, having a significant effect on worldwide investment markets. The FSA have therefore stated unequivocally that they will not hesitate to take action where they find bad practice.

Regarding intermediary files reviewed they found the following:

• In 33% of cases there was an inadequate assessment of affordability
• In 50% of cases there was an inadequate assessment of customers' suitability
• In over 50% of cases customers had self certified their income but it was not clear in many cases why they had been advised to do this.

Also, significant numbers of consumers were advised to re-mortgage, thereby incurring early repayment charges, without the adviser being able to demonstrate that this was beneficial to the customer.

For Lenders the main weaknesses were found in their lending policies:

• None of the lenders adequately covered all relevant responsible lending considerations in their policies. For example, some firms’ lending policies contained unclear affordability or self-certification requirements.
• In many cases, lenders did not apply their own policies in practice. For example, some firms failed to check the plausibility of information, as required by their own lending policy.

Ateb view:

Getting things right in this area is not rocket science. The outcome of this review and obvious poor practice are down to lack of care and greed. We expect FSA enforcement to sanction firms heavily in this area over coming months and lenders will undoubtedly tighten up on their lending policies.

Action required by you:

You can read more about the review at: http://www.fsa.gov.uk/pages/Library/Communication/PR/2007/081.shtml

Return to Features List or Contact Us

17. FSA produce ‘Mortgage Factsheet’

The FSA consumer booklets and factsheets cover a wide range of topics. They are written in plain English and are a good starting point if you want to give clients general information.

The FSA have redesigned their publications following consumer research to make them more appealing, engaging and easier to read and understand.

The FSA have just released a mortgage factsheet - this can be an excellent complement to your suitability letter.

Ateb view:

These are well written guides and firms can order up to 2000 copies, we fully endorse firms building these guides into their process.

Action required by you:

You can get more information and order copies of this and other guides from the FSA website. http://www.moneymadeclear.fsa.gov.uk/publications

Return to Features List or Contact Us

18. FSA sets out principles based future for general insurance regulation

In June 2007, the FSA published a consultation paper proposing to reform the rules that firms need to follow when carrying out general insurance business with customers.

These proposals have arisen because the current rules cover not only typical general insurance such as motor or household, but also non-investment insurance (protection) products, more typically sold by IFAs and mortgage brokers. The FSA is concerned that the selling practices used for the latter products is not always of sufficient quality.

It is therefore proposing that the new regime will allow a more principles-based approach for true GI products, while non-investment insurance products are likely to attract additional rules.

For protection products (Payment Protection Insurance (PPI), critical illness cover, income protection and term assurance), the FSA is proposing a small number of additional rules carefully targeted to improve selling practices in areas where consumers are losing out.

Some of these new measures will apply to all protection products, for example, a new standard to ensure balanced oral disclosure to help consumers make informed purchasing decisions. One of these - a requirement for firms to provide information on price orally to the customer where a discussion takes place - will have particular impact on PPI markets. Some measures will apply only to PPI, such as extending the cancellation period from 14 days to 30 days.

Following the consultation, the new general insurance regime is likely to come into effect in January 2008 with firms being allowed a transitional period for implementation.

Ateb view:

You will need to monitor these changes. The majority of you who sell primarily life and critical illness products are unlikely to see major change. Those who sell PPI may be significantly impacted.

Action required by you:

You can read more at http://www.fsa.gov.uk/pages/Library/Communication/PR/2007/077.shtml and at http://www.fsa.gov.uk/pubs/newsletters/gib_newsletter9.pdf

Return to Features List or Contact Us

Important Note:

The ATEB Newsletter is intended to provide general guidance on areas of compliance and T&C; however it is not a replacement for the main Rules and Guidance contained within the FSA Handbook. We welcome all feedback. If you have any feedback or questions relating to any articles then please direct them to your local ATEB consultant or the newsletter editor Steve Bailey email steve@atebconsulting.co.uk Unless you have consulted specifically (as part of a regular visit) with ATEB on a particular issue then ATEB Consulting accept no liability for any actions taken based on the information contained solely within the newsletter.

Contact Us:

Ateb Consulting
The Old Post House
29 Nedderton Village
Northumberland
NE22 6AX

T: (01670) 822984
M: (07703) 576951
E: steve@atebconsulting.co.uk
W: www.atebconsulting.co.uk