Culture? What culture.

I don't know. You look out for blogs on compliance and then ,like proverbial London buses, two come along at once.

You may recall moderately recently, probably in a recent FCA Regulation Round Up that there was some discussion and reference to looking at a firm's culture as a part of the way that they would be  regulated. I was asked by a client recently what exactly that meant and how could culture apply to a sole trader. It is a very good question. On the face of it, this may bring to mind a number of images : customer service culture - have a niyce da'ay (spelling deliberate to emphasise pronunciation) or things like Every Little Helps or ....it's got our name on it and so on.

However, it's not that and I suggest it can be best summarised as follows:-

Recently (over the past 18 months or so)  the FSA and then the FCA issued a survey to a number of firms, following on workshops on Risk Analysis. They were not just ordinary surveys, for those of you who seemed to think they were. They were, to coin a phrase, exactly what it said on the tin when they invited you to complete them and it said in bold letters something along the lines of "Notice of Regulatory Review" in the email or letter you received. BTW, as my children would say, if you failed to respond to one of these surveys you would a notice threatening enforcement action. That made them pretty serious.

In these surveys, firms were asked a large number of fairly intrusive questions about how they operated and controlled the business, the nature of the business they carried out and so on. The surveys lasted between 90 and more than 180 minutes depending upon firms.

Those questions more or less defined what the FCA mean by culture and in some respects they have set out their stall for small firms over the next few years in that survey. If you completed one of these surveys, you will already know where you are achieving and where you are falling down. If you didn't have  the opportunity, then i will be  providing a series of blogs over the next few months on the matters arising in it and suggesting how they can be  addressed.

But first, lets get MMR in place and working properly.