Compliance Consultancy & Training

SYSC now includes the requirements of the SM&CR, but the earlier chapters are crucially important for those accountable under the Regime and their practical responsibilities for their firm’s arrangements. So this week, to ease us gently into 2020, we’ll take a look at the part played by the FCA’s Senior management arrangements, Systems and Controls Sourcebook, or SYSC, and what it means for firms and for Senior Managers.

High on the FCA’s cross-sector priorities for 2019/20 is ‘operational resilience’. The Regulator has recently turned its attention to technological changes and advances, particularly where these might impact on consumers or on regulator supervision, so it’s no surprise that high on the agenda is potential disruption caused by failure – or something more nefarious – of IT systems and other technologies.

There is some concern about how a customer’s vulnerability can be collected, recorded and acted upon, given the constraints of the General Data Protection Regulation. So to help firms we’ll be focussing on the interplay between vulnerabilities and the GDPR in a series of articles between now and the first half of 2020. First up is the issue of explicit consent.