The Compliance Doctor

Receiving a query from the FCA is one of the most stressful moments in a compliance professional's calendar. Whether it's a supervisory information request, a data query, a Dear CEO letter follow-up, or the opening move in a more formal supervisory engagement, how you respond matters enormously — and most firms simply aren't prepared.

In this episode, we're talking about the FCA Query Response Pack — what it is, why every FCA-regulated firm should have one in place before they ever need it, and how a structured, well-prepared response framework can protect your firm, your senior managers, and your regulatory relationship.

What we cover in this episode:

We begin by looking at the different types of FCA contact that typically require a formal response — from routine supervisory data requests and thematic review questionnaires through to more serious Section 165 information requests and supervisory notices. Understanding the nature of the query you've received is the critical first step, and many firms underestimate how different the appropriate response strategy can be depending on the type of contact involved.

We then walk through the core components of an FCA Query Response Pack — the internal triage process, the escalation framework, the roles and responsibilities of senior managers under SMCR, how to coordinate your response across legal, compliance, and operational functions, and the documentation standards you need to maintain throughout the process.

We discuss the importance of response tone and framing — because the FCA reads between the lines. An overly defensive response can signal problems that weren't originally on their radar. An incomplete or poorly organised response can invite further enquiry. And a delayed response, without a properly managed extension request, can escalate a routine query into something far more serious.

We also cover the common mistakes firms make when responding to FCA queries — including responding too quickly without proper internal review, failing to identify the appropriate Senior Manager with accountability for the subject matter, providing inconsistent information across different response channels, and neglecting to retain proper records of what was submitted and when.

Why this matters right now:

The FCA's supervisory model has become significantly more data-driven and proactive. Firms are receiving more frequent information requests as the regulator seeks to identify harms earlier and intervene faster. The Consumer Duty has added a new layer of supervisory interest in how firms evidence their outcomes, and the FCA has made clear that it expects firms to be able to respond to queries promptly, accurately, and with appropriate senior manager oversight.

Firms without a structured response framework are operating at a significant disadvantage. When a query lands on your desk, the last thing you want to be doing is working out your process from scratch while the clock is ticking.

The practical takeaway:

By the end of this episode, you'll understand the anatomy of a well-managed FCA query response process, the internal governance steps that should sit behind every formal response, and the documentation you need to protect your firm if a query escalates into a deeper supervisory engagement.

If you want a ready-built solution, our FCA Query Response Pack is available to download directly from Compliance Consultant at complianceconsultant.org — a comprehensive, practical resource built by qualified regulatory consultants.

Who this episode is for:

This is essential listening for compliance officers, MLROs, legal counsel, Chief Risk Officers, and any Senior Manager with regulatory oversight responsibility at an FCA-authorised firm. If your firm has ever received — or is likely to receive — a formal communication from the FCA requiring a response, this episode will give you the framework and confidence to handle it properly.

Visit us at complianceconsultant.org or call us on 0800 689 0190.

Most firms have a complaints process. Far fewer have one that actually drives improvement — and the FCA's thematic findings make clear that the regulator can tell the difference.

Complaints handling sits at the heart of the Consumer Duty framework. The FCA expects firms not only to resolve complaints fairly and promptly, but to analyse them systematically, identify root causes, and use that intelligence to drive measurable improvements in customer outcomes. Logging complaints and meeting DISP deadlines is the floor, not the ceiling. What happens with that data afterwards is where firms are increasingly being judged.

In this episode, we examine what genuinely effective complaints Root Cause Analysis and Management Information reporting looks like — and why getting it right matters not just for regulatory compliance, but for the commercial health of your firm.

Whether you are a compliance officer, an MLRO, a customer outcomes lead, or a senior manager with Consumer Duty accountability under SMCR, this episode gives you the practical grounding to assess whether your current complaints MI is fit for purpose.

We cover:

— Why complaints data is now a primary Consumer Duty evidencing tool and how the FCA expects it to feed into your annual board report

— The difference between complaints handling and complaints intelligence — and why firms that conflate the two are storing up significant regulatory risk

— What Root Cause Analysis actually requires: moving beyond symptom-level categorisation to identify systemic failures in products, processes, communications, and customer journeys

— How to structure your RCA methodology so findings are consistent, comparable over time, and capable of generating actionable management information

— The MI your board and senior management actually need: what good complaints reporting looks like, what metrics matter, and how to present data in a way that supports genuine governance oversight

— FCA DISP requirements and how your complaints MI framework should sit alongside — not instead of — your regulatory reporting obligations

— The Consumer Duty connection: how complaints patterns can evidence, or undermine, your firm's ability to demonstrate good outcomes across the four outcome areas

— Vulnerable customer considerations: how your RCA process should identify whether complaint patterns disproportionately affect customers in vulnerable circumstances

— How personal accountability under SMCR applies when complaints MI fails to reach the right people or triggers no meaningful action

— Practical guidance on review frequency, escalation triggers, and embedding complaints intelligence into product governance and operational risk frameworks

This episode is essential listening if your firm:

— Produces complaints MI that satisfies reporting deadlines but generates no meaningful management action

— Has not reviewed its RCA methodology since Consumer Duty came into force

— Is approaching an FCA supervisory visit or preparing its Consumer Duty annual board report

— Has recurring complaint themes that have not been traced back to a documented root cause and remediation plan

Resources mentioned in this episode:

Compliance Consultant's Complaints RCA & MI Reporting Template is a ready-to-use, professionally structured toolkit designed for FCA-regulated firms. It combines a robust root cause analysis framework with a fully formatted MI reporting template, enabling compliance and customer outcomes teams to move from complaints data to actionable intelligence — efficiently and to a standard that reflects current FCA expectations under Consumer Duty and DISP.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.

Every year, FCA-regulated firms go through the motions of annual certification — and every year, the FCA finds firms that can't evidence what they've actually done. Certification under SMCR isn't just a box-ticking exercise. It's a legal obligation, and when things go wrong, the consequences land directly on senior managers.

In this episode, we're cutting through the complexity of the annual certification requirement and showing you exactly what a well-structured Annual Certification Assessment Template looks like — and why having one in place could be the difference between a clean regulatory record and an uncomfortable conversation with your supervisor at the FCA.

What we cover in this episode:

We start with the basics — who actually needs to be certified, what "fitness and propriety" genuinely means under the SMCR framework, and why so many firms are still getting this wrong years after SMCR came into force across the full financial services sector.

We then walk through the structure of a robust Annual Certification Assessment Template — the sections that matter, the evidence you need to gather, the conditional fit and proper determinations that firms routinely miss, and how to document your reasoning in a way that would stand up to regulatory scrutiny if challenged.

We discuss the difference between a certification process that looks right on the surface and one that is genuinely defensible — because the FCA's supervisory work has made clear that they are looking beyond policies and procedures to the quality of the evidence that underpins them.

We also cover some of the most common failure points we see when reviewing firms' certification frameworks — including incomplete fitness and propriety assessments, missing financial soundness checks, inadequate consideration of criminal records and regulatory history, and certification sign-offs that aren't properly linked to role-specific conduct risk.

Why this matters right now:

The FCA has been explicit in its supervisory priorities that individual accountability is at the heart of its regulatory agenda. SMCR was designed to ensure that people in positions of responsibility can be held to account — and the annual certification requirement is one of the most important mechanisms for making that accountability real and demonstrable.

Firms that treat annual certification as an administrative formality are exposed. Not just to regulatory censure, but to the reputational and operational consequences of having certified individuals in post who should not have been — or worse, of being unable to demonstrate why they were certified at all.

The practical takeaway:

By the end of this episode, you'll have a clear picture of what a best-practice Annual Certification Assessment Template should contain, how to structure your firm's certification process to meet FCA expectations, and what documentation you need to maintain to evidence your decisions.

If you want a ready-built solution, our Annual Certification Assessment Template is available to download directly from Compliance Consultant at complianceconsultant.org — built by qualified regulatory consultants who know what good looks like, ready to use, and designed to integrate with your existing SMCR framework.

Who this episode is for:

This episode is essential listening for HR professionals, compliance officers, MLROs, Chief Risk Officers, and any senior manager with oversight responsibility for SMCR certification at their firm. Whether you're at a large authorised firm or a smaller directly authorised business, if you have certified persons on your register, this episode is for you.

Visit us at complianceconsultant.org or call us on 0800 689 0190.

References: FCA SMCR — Certification Regime (FCA Handbook, FIT, SYSC 27); FCA Finalised Guidance FG20/1 — Certain aspects of the FCA's supervisory approach to the certification regime; PRA/FCA Joint Consultation on SMCR implementation.

Most compliance failures don't come out of nowhere. They come from regulatory changes that were signalled months — sometimes years — in advance, and firms that simply weren't watching. Regulatory horizon scanning isn't a luxury reserved for large firms with dedicated regulatory intelligence teams. It's a fundamental risk management discipline, and the FCA expects every authorised firm to be doing it.

In this episode, we're talking about the Regulatory Horizon Scanning Playbook — what it is, how to build a structured process that works in practice, and why firms that get this right consistently outperform their peers when new regulatory requirements land.

What we cover in this episode:

We start by defining what regulatory horizon scanning actually means in a UK financial services context — because there's a significant difference between occasionally glancing at the FCA's website and running a systematic, evidenced process that feeds directly into your firm's risk framework, board reporting, and strategic planning cycle.

We walk through the key sources every compliance professional should be monitoring — from FCA consultation papers, policy statements, and Dear CEO letters, through to HM Treasury publications, PRA communications, and international developments from bodies like FATF and the Basel Committee that have a direct bearing on UK-regulated firms.

We discuss how to structure your horizon scanning output — how to assess regulatory impact, categorise emerging requirements by probability and proximity, and translate intelligence into actionable implementation plans with appropriate lead times built in.

We also cover the governance dimension — because horizon scanning only adds value if the intelligence reaches the right people at the right time. We look at how to integrate it into your compliance monitoring programme, how to present emerging regulatory risk to your board in a way that drives genuine engagement, and how to evidence your horizon scanning activity to the FCA if challenged.

Why this matters right now:

The UK regulatory landscape is moving faster than at any point in recent memory. Consumer Duty, the review of Payment Services Regulations, the evolution of cryptoasset regulation, and the FCA's accelerating use of data-led supervision are all creating an environment where firms that aren't scanning the horizon are already behind.

The FCA expects firms to be forward-looking in their risk management — not simply reactive. Firms without a structured horizon scanning process are exposed to last-minute implementation rushes, inadequate board engagement, and the consequences of being caught unprepared when a new requirement lands.

The practical takeaway:

By the end of this episode, you'll understand what a best-practice horizon scanning process looks like, how to build one proportionate to your firm's size and complexity, and how to turn regulatory intelligence into a genuine operational advantage.

Our Regulatory Horizon Scanning Playbook is available to download at complianceconsultant.org — built by qualified regulatory consultants who track the landscape daily, and ready to implement immediately.

Who this episode is for:

Essential listening for compliance officers, MLROs, Chief Risk Officers, NEDs with regulatory oversight responsibilities, and any senior manager accountable for the firm's regulatory risk management framework.

Compliance Consultant — Making Compliance Work.

Visit us at complianceconsultant.org or call us on 0800 689 0190.

Follow us on LinkedIn, Facebook, Instagram, and Pinterest — search Compliance Consultant UK.

References: FCA Business Plan 2025/26; FCA Three-Year Strategy 2025–2028; Financial Services and Markets Act 2023; FATF Mutual Evaluation — UK, 2024 update; FCA Consumer Duty Finalised Guidance FG22/5; HM Treasury Financial Services Future Regulatory Framework Review.

In this episode of the Atomic Impact Podcast, host Jason Osborn speaks with Lee Werrell, owner of UK Compliance Consultant Limited, also known as Compliance Doctor, about building a successful regulatory compliance consultancy in the financial services sector. Lee shares insights on the importance of relationships, dialogue over hard selling, and creating practical frameworks that help businesses navigate complex compliance requirements with speed and clarity. He also discusses lessons learned from decades in business and his goal of scaling Compliance Doctor into a seven-figure consultancy.With Jason Osborn -  https://www.linkedin.com/in/jasonaosborn/

The main document, thoroughly examines the provisional agreement for the European Union’s Payment Services Regulation (PSR) and Third Payment Services Directive (PSD3). This regulatory shift introduces a "fraud liability revolution" by dramatically increasing the financial responsibility of Payment Service Providers (PSPs) for fraud losses, especially those resulting from impersonation scams.

Crucially, the agreement extends financial accountability beyond the financial sector by establishing a new liability chain for online platforms and electronic communications providers who fail to cooperate in fraud prevention. PSPs are consequently compelled to overhaul operations, including implementing mandatory Name-IBAN verification systems, offering human customer support, and strengthening open banking standards ahead of the formal adoption and implementation timeline.

The podcast outlines significant amendments and guidance concerning payment services and electronic money institutions within the UK, primarily focusing on strengthening consumer protection and market integrity. Key changes include a revised safeguarding regime for relevant funds, detailing how these funds must be held and protected, particularly in the event of a firm's failure, and introducing specific safeguarding audit requirements with a new exemption for smaller firms. Furthermore, the texts address capital requirements, operational risk management, and security measures like strong customer authentication, alongside clarifying reporting obligations and enforcement powers under the Payment Services Regulations 2017 and Electronic Money Regulations 2011. The podcast aims to provide clarity for businesses operating in this sector and enhance regulatory oversight, including the new Fit & Proper requirements.

Financial Conduct Authority's (FCA) intention to consult on a compensation scheme for motor finance customers who were subject to unfair practices. This initiative stems from a detailed review and a Supreme Court ruling that identified instances where lenders acted unlawfully due to undisclosed commission payments to car dealers. The FCA aims to establish an industry-wide scheme to ensure fair, consistent, and efficient compensation for consumers, potentially covering agreements dating back to 2007. The consultation will address crucial aspects like the scope of the scheme, redress calculation methodology, and interest payments, aiming for a launch in 2026. The FCA also advises both firms to assess potential liabilities and consumers to complain directly without necessarily involving claims management companies.

One document details a compliance consultancy's offerings, including FCA authorisation, benchmark audits, training, and tailored advice, highlighting their expertise in helping businesses navigate complex financial regulations and avoid penalties. The second source, a policy statement from the Financial Conduct Authority (FCA), announces new, more flexible rules for mortgage advice, affordability assessments, and remortgaging, aiming to simplify processes for consumers while maintaining protection under the Consumer Duty. This FCA document also addresses feedback from various stakeholders and explains the rationale behind retiring certain non-Handbook guidance, ensuring firms continue to treat customers fairly, particularly those with expired mortgage terms.

The Financial Conduct Authority (FCA) has published a revised Enforcement Guide (ENFG) and associatedinstruments, which come into effect on 3 June 2025. This revision incorporates feedback on earlier proposals and aims to provide greater transparency regarding enforcement investigations. Key changes include a revised publicity policy for investigations, specific approaches to investigating unauthorised activity and individuals, and clarifications on the use of various statutory powers. The revised guide is abbreviated to ENFG and replaces the previous version.