MARKET INSIGHT
individuals remain competent to carry out their work.
They expect most individuals will be able to continue completing this training while on furlough or working from home, however the FCA will temporarily allow firms to let individuals in exceptional circumstances carry over any uncompleted training hours to the next year. Firms should record their decision and the reasons for it.
What are the regulatory risks to dealers? In these challenging times do not cut corners. There are no excuses for low enquiry level or the pandemic, so focus is needed, as this could lead to exposure not only with the regulator, but lead to an increase in customer complaints, particularly if Claims Management companies pick up on weaknesses. Make sure you can monitor your FCA process properly to maintain consistent compliance, if you can’t measure it, you can’t manage it!
• Ensure that all customer communications are clear, fair and not misleading
What about when it comes to being flexible with customers’ needs? For suitability assessments, the FCA recognises that face-to-face meetings are not possible. In such circumstances, they expect firms to use other methods to conduct a suitability assessment, such as phone calls; the FCA would then expect a dealer to send out the assessment without delay, whether online for those customers that use online or email services or by post.
What about training - this is always critical, but is it relaxed a little now? An update was published on 27 May on the FCA website, which is particularly relevant to dealers carrying on insurance distribution activities, saying they must ensure that each relevant employee completes a minimum of 15 hours of professional training or development in each 12-month period.
During the current pandemic, the FCA expects firms to continue to demonstrate that relevant
What about with staff coming back from furlough - what should dealers bear in mind? As you unfurlough, be aware that sales staff will be coming back to a very different working environment as you prepare for social distancing in your showrooms, make sure your FCA process aligns with your social distancing policy and process. Re-educate sales staff in the importance of not exposing you to FCA non-compliance, do not take your eye of the ball of maintaining and evidencing FCA compliance. Horizon scan FCA updates, this is a changing landscape as restrictions are lifted, subscribe to the daily/weekly FCA updates. Keep up to date on FCA GABRIEL reporting - do not miss the deadline. The FCA published final notices of firms on 21 May and eight of these were car dealers.
What should dealers be considering? We know the customer route into dealership has moved to a more online journey, e-commerce, distance-selling, so make sure your website is compliant, is clear and transparent for the customer-initiated purchase, and clearly shows your FCA status and permissions. When it comes to social distancing, review and understand where there are potential coronavirus hotspots, to reduce the risk for exposure inherent in a traditional paper-based process. Also, consider how you make this contactless
and can substantiate and evidence compliance, from finance suitability to purchase decision and handover.
How can Automotive Compliance help motor dealers?
As the industry re-emerges into life post lockdown, Automotive Compliance has released the ‘Covid-19 Safe Compliance’ system to embrace the new world of social distancing.
Using our motor retail regulatory expertise and our team’s hands-on dealership experience, we have further developed our systems and processes to keep sales departments and customers safe and ensure the dealers’ FCA compliance is maintained. Our ‘Covid-19 Safe Compliance’ system not only strengthens a dealers FCA Compliance, it is both paperless and contactless, multi- platform compatible, whether PC-based, iPad or tablet and compliments whichever method of transaction the dealer is embarking on, whether that be online or a social distancing sale in the showroom, culminating in a physical showroom handover, reserve & collect or home delivery. Our Covid Safe FCA procedure in eliminating or minimising the now demonised potentially contaminated paperwork and pens always maintains a minimum two metres distance. In conjunction with the covid safe measures, dealers are already implementing this only further enhances and evidences the dealer’s commitment to protect their staff and customers. Adding the additional security of even stronger FCA Compliance from the award-winning industry experts de-risking the business from regulatory exposure is an extra bonus.
Thanks to Automotive Compliance for their help putting this article together.
For more information: 01452 671570 or
www.automotive-compliance.co.uk
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