Someone asked IFAC this week for a Conflict of interest register.
That generated some energy in the sedate world of compliance. Feathers rustled and fluttered. Voices were raised. Oh, the excitement for those of us in the dry world of compliance, more often known as Shane Warne's fun-police. A sort of Puritanical Zeal takes over in compliance - worked up by the dread thought that "Someone, somewhere is having fun and making money" and we dash off to stop it The business prevention unit, some call us, others say, after a few drinks, “Compliance is the new C word.”
Finally, agreement was reached that a mandatory register requirement is a bit "OTT" for a small IFA firm. After all, conflicts are all around us, family, friends, social mixing with business, invitations to the races, and, perish the though, drinks paid for by your client in the pub. Undeclared earnings? It is really a case of managing the conflicts, rather than stamping them out. The FCA Handbook - our bible - states that records should be kept, but not a specific register – though we think it makes sense to be able to recall the conflicts when needed. So, with this in mind we attach a draft register, and have added this document to the document library in BAT for members to peruse. Click here to view
Principle 8 of the Financial Conduct Authority's Principles for Businesses requires a firm to "manage conflicts of interest fairly, both between itself and its customers and between a customer and another client. Under the Markets in Financial Instruments Directive investment firms are required to maintain and operate effective organisational and administrative arrangements."
Click here to download the IFAC policy.
IFAC members can view as usual in the Bat document library.