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The breach register stores all company breaches securely and can be reviewed when and if required.

Arguably this is the single most important register for SMF16s AND SMF17s to keep.

How so?  Well check out and you will note that it is a criminal offence to conceal from the FCA or PRA information on the advisers under your control.


FCA require all firms to keep a breach register.  In fact this is no surprise to IFA firms who have been keeping breach registers since the days when your compliance director worked beside a bookcase displaying lever arch files marked in black marker with Complaints, T&C, Procedures, AML and, of course, BREACHES.

See also FCA rules under Supervision and the COCON rules that apply to all.

If you have procedures, and you work as SMF 16,then you have an obligation to keep a record when policy breaches are made.  This could be inducement related, failure to produce a file for checking in good time, or a more serious breach of FCA rules.

FCA mandate that you use REP 008 ot make reg data returns of breaches. If you run more than 5 mortgage brokers, protection advisers or IFAs, then you need to keep a register, and keep updating it.  What better way to manage staff than by saying “I am going to breach you…”

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