Former chief executive of the National Association of Commercial Finance Broker Adam Tyler covers compliance issues that the NACFB has come across while helping its members
Now that we have visited 150 of our brokers and seen their working practices up close, what kind of issues are we picking up on?
A disaster recovery plan is essential, but it’s no good if it exists as a paper document in a drawer in a filing cabinet in an office that’s on fire. The NACFB itself lost a number of pull-up show banners to a basement flood six months ago and we were lucky not to lose any important files at the same time – had the water levels risen another ten inches, we would have started to lose things that were irreplaceable.
The obvious answer to these problems is the paperless office.
And even that is no kind of silver bullet if your important document is on a laptop that gets left on the 11:32 Edinburgh train, or on a corrupted hard drive, or in a cloud storage service accessible only by a staff member who left three weeks ago.
'Paperless-ness', is just a step in the right direction towards a best-practice solution. It’s certainly not the case that “paperless-ness means compliance”. But on those occasions when we walk into a working office that resembles a hurricane in a printing press, we can usually be sure that other “sub-optimal” working practices are buried not so far below the surface.
The other issue we come across is an absence of Training & Education. Not just relevant training; any training. As you might expect, this is principally a problem for the smallest broker firms, the small traders and the ones who wouldn’t recognise the phrase “down time” if they read it in a Shakespeare sonnet. Part of the reason we offer a set of five modules in our own Training & Education programme is that they answer the two questions; “What kind of training should I be taking? Where can I find it?”
When we do come across a member with a calendar of training plans and a secure set of back-up copies of everything that matters, then that’s the first two hurdles cleared, and these things are nominally quite easy to achieve.
We’re also making it much easier for our Patrons to train our members, either by inviting a suitable sample to an event, or by adding to our CPD programme informative documents that leave a broker educated in a specific field or product. It all counts towards, ultimately, giving the client a better and fuller service.
And in turn, this means that we’re expecting to find our visits easier and more efficient as 2017 goes on, because we’re already putting in place the things we think would have benefited the brokers who we’ve already seen. On the other side of that coin, the ones who put their hands up and yelled “Me first! See me first!” are precisely the ones who you’d expect to have done their homework and brought an apple for teacher, so perhaps the second half of 2017 will introduce us to some brokers who need a little more help to attain top levels of compliance.
But we will work with them, and we’re putting the tools in place to ensure that by the time we knock on their door, they’ll hopefully have everything tidy and no important papers in flood zones or by open flames. The Treating Customers Fairly, the Anti-Money Laundering, all of that comes on top of the basics.