We have recently updated some of the Compliance File Review Process to provide more information and clarity.
You may recall seeing the tab called ‘compliance’ in each case on OMS. This tab has been recently revamped so that it mirrors the checks that the compliance T&C team are completing when they review your files.
Where remedial actions are needed, these will clearly show in the box on the top right of the page. The relevant compliance check section will explain why the element has not met the standard.
There are three types of guidance:
- Grading Remedial action
- Items to fix
- Training observation
Only the grading remedial actions are the ones that have contributed to the red, amber or green rating you have been given on the file review.
The items to fix remedial actions are those that you need to fix, but have not contributed to the grading. The training observations do not contribute to your grading, but you should look to ensure they are addressed in future cases to protect yourself from complaints or compliance risks.
Green, Amber Red Rating
As you are aware, each file is given a red, amber or green rating, which is explained in more detail as follows:
Green is where you have met all the minimum standards on the file. There may still be some non-graded remedial points which should be actioned or some training notes to consider for future cases
Amber is where the minimum standard is not met, and there are some errors. This may mean the file may not withstand a compliance challenge from the FCA or the file could expose you to an upheld complaint.
Red is where there is clear client detriment caused by wrong advice, or the case is found to be fraudulent.
The team are also working very hard on file-checking consistency so that regardless of the person reviewing your file, you are getting consistent guidance on expectations. This is a challenge as each case is different, and advice issues can be subjective.
We are more than happy for you to question any decision. Still, with the new transparency on what is being checked and the detail around why a particular rating was given, we hope you will find this will benefit you in achieving regular green passes.
Regards
Liz Syms, CEO
Any Questions or Queries Contact : compliance@connectmortgages.co.uk