A one-half day workshop or two half days
Background to COCON and its role in the Senior Management Regime
Origins of COCON in APER and FSA/FCA enforcement experience
Sanctions for breach of COCON
THE SCOPE OF COCON
To whom does COCON apply?
What applies to whom?
To what conduct does COCON apply?
Where does COCON apply?
Assessing COCON Compliance
FCA factors for considering whether COCON has been broken and when to take enforcement action
INDIVIDUAL CONDUCT RULES AND EXAMPLES OF THEIR BREACHES
For individuals, directors and managers
- Due skill, care & diligence
- Open & co-operative with all regulators
- Due regard to customers’ interests and treat them fairly
- Proper standards of market conduct
- Consumer Duty
SENIOR MANAGER CONDUCT RULES AND EXAMPLES OF THEIR BREACHES
Reasonable steps to ensure
- Business for which you’re responsible is controlled effectively and complies
- Any delegation is to an appropriate person & you oversee discharge of responsibilities effectively
- Disclosure appropriately of information which regulators would expect to receive