Independent review and analysis

The clock is ticking towards implementation

The FCA has recently released the results of a comprehensive survey carried out on 5400 firms, attempting to ascertain how ready they are for MMR implementation in April 2014.

Completion of the survey was not compulsory, but it did achieve a response rate of 68%. Interestingly, two thirds of the respondents said they were on track, with the remaining one third believing they can get back on track by drawing up an action plan. Overall it was found that lenders were less prepared than intermediaries, but it was recognised they have more to do in the preparation stages due to their size and the complexity of the issues.

However, the 32% of firms who did not respond could be in need of some help.

MMR has a defined start date of the 26th April 2014, but in reality, to use Treating Customers Fairly and Conduct Risk campaigns as examples, it will necessitate cultural changes for many companies over a longer period of time and we believe assistance will be needed to review how effective these changes are as the journey progresses. Help is at hand from independent third party companies like Rockstead who can provide various solutions; the provision of consultants to help with short term staffing needs should staff be seconded to help with MMR implementation and training, are good examples of support services or even the auditing of calls in the fully advised sales call process.

The key to a smooth implementation and ongoing monitoring of any changes required is to provide a robust audit trail to ensure compliance with the new rules. A planned strategy should be in place already, but please give us a call if you feel you could benefit from our services.

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