It's about time I told you why you should not use Compliance On Call. Strange thing to do, but I think you'll soon get the idea.
1) Your last monitoring visit was o.k. and you've still got the same staff and systems.
You're right, of course; the customer always is. However, in addition to the legislative changes, the regulators themselves have moved the goalposts. In their attempts to attract more members while adhering to the Principles of Monitoring they have brought in annual review requirements and are looking into more than just your casework. Also, and probably more significant, they may have missed a key default last time. Of course, I might not spot it either and they may miss it in your next visit and so on.
2) You're a qualified IP and you've been dealing with compliance for years.
Again, you are right. If you sit down and think only about compliance for a few days, then spend a few hours planning a review of a representative sample of your cases, then do the review covering all of the compliance criteria used by 5 of the regulatory bodies, write it up in a report...when was the last time things were quiet enough for you to do that??
3) Compliance On Call is too expensive.
You are, as ever, perfectly correct (to the sound of gritting teeth). Even the full day rate applicable from January equates to only £200 an hour for the time I spend in your practice. I don't charge for the planning and reporting time so my actual rate spent on the whole visit is charged at around a third of that, to say nothing of the inordinate amount of CPD that you indirectly benefit from. Of course your rates are so low that it is cheaper to do the job yourself.
4) You have got a compliance team, a risk committee and your firm's turnover is bigger than the Bolivian National Debt, so you don't need an external review.
Of course, Sir. That is why, when you are about to receive a regulatory visit you are able to lie back, relax and take a break, safe in the knowledge that they won't find anything. Even after I've had a look, the odd issue will arise, but wouldn't you feel happier for that one extra review?
5) You completed your self-certification sheet last year, said everything was compliant and didn't hear a thing. All you need to do is repeat it this year.
Great! The IPA had a complete new monitoring system to set up, with staff to train and visit formats to create. They won't have cut their new monitors' teeth on the tough assignments, so there is every chance that those visited last year were the lucky ones. If you were a monitor looking for a bit of a challenge this year, who would you visit, the IP with an action plan showing new procedures introduced as a result of an external review or the one who signed off his own cases to say nothing was wrong?
6) You are using another compliance reviewer.
You've got me there. I cannot expect you to drop them for me. Just keep reading this blog and talking to other IPs about Compliance On Call. If anything technical crops up that you just want to talk through without charge, call your present supplier but if they cannot help I won't be offended if you give me a bell. Remember that I'm in compliance because I love the technical stuff, in the same way that you get a buzz when you start a new trader.
I know Compliance On Call is constantly updating to stay as good as I can make it and as we expand we'll only get better, so when you do give us a try in a couple of years we'll be smokin'!
7) An IP you know/work with/beat at poker reviews your cases for you and you review his.
That should be o.k. then..........but you might want to check that you're both looking at the right stuff and finding enough. You could give me a call and I'll review some of the cases you've already reviewed. If I cannot find anything, read the first section of this paragraph (That should ......).
8) I know I need an outside review, but now is not a good time.
Fine. Is there ever a good time to have an over-zealous technical-obsessive trawl through your cases and criticise your administration just because he thinks it is fun? If you really have a good reason, not just cold feet or apathy, for putting off the call use the form on the email that told you about this Blog. That will give Compliance On Call everything we need to set up a plan and call you when we think you should have a visit. (I'm not exactly itching to spend every week day on visits with everything else fitted into weekends and evenings, so I'm not going to tell you you need a visit unless you really do...I just don't want to work that hard).
