What should be your action items for 2017?
This is our list of hot compliance action items for licensed companies:
- Has the company included the suitability clause in its standard client agreement for new clients? The deadline is 9 June 2017.
- Has the company completed the revision / amendment of client agreements with existing clients?
- Have all licensed individuals got access to their ePortal accounts to make their own notifications online from 1 February 2017 onwards?
- Who are the company's Managers-In-Charge (MIC) for each of its eight core functions as set out in the SFC's circular of 16 December 2016? The SFC needs to be notified by 17 July 2017.
- Does the company need to get any of its MICs licensed, or approved as ROs?
- Has the company considered how the SFC's circular on compliance with suitability obligations of 23 December 2016 affects its business operations?
- Has the company considered how the SFC's circular on triggering of suitability obligations of 23 December 2016 affects its business operations?
- Does your compliance manual need to be updated in view of the forthcoming regulatory changes, or changes to your business activities?
- Should your existing compliance monitoring plan be updated to cope with recent changes?
- Does your 2017 CPT plan cover the new regulatory changes?
- Does the company need to schedule compliance refresher training for any topic (e.g. how to use the SFC's online portal for notification submission)?
- How ready are you for an SFC onsite inspection?
New licensing forms for corporate applicants and licensees
Applications and notifications by licensed companies will need to be made using the new licensing forms after 1 February 2017. They are already available on the SFC's website. If you are working on notifications or applications to be submitted after 1 February 2017, you should start working on the new forms now.