If you are SMF16 or just an SMF3 for your regulated retail advice firm, then you need to set exams for staff, monitor that they are taking those exams, and track performance.
Under the part of the FCA rulebook marked TC or https://www.handbook.fca.org.uk/handbook/TC
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It is the vaguest and the shortest of all sections of the FCA handbook, and therin lies a trap. The trap is that both these qualities can be weaponised and used against you.
Consider the start of the training rules – in TC1.1.3 G and the grand opening line
“The competent employees rule is the main requirement relating to the competence of employees.”
This takes you to SYSC 5.1.1 R and you get
“A firm (other than a common platform firm) must employ personnel with the skills, knowledge and expertise necessary for the discharge of the responsibilities allocated to them.”
And, as far as the FCA are concerned, the less they add to that the more they can rely on principles, and the 12 principles for business is in effect the FCA rule book. See https://www.handbook.fca.org.uk/handbook/PRIN/2/1.html
T&C exams must be automated.
- Auto-invigilate (BAT fails the participant if they start browsing around and hopping in and out of the exam showing on screen)
- Auto-score (BAT marks in realtime the answers)
- Auto upload the relevant training material (in same location as exam or as required)
- Build reports of activity and demonstrate compliance with the minimum requirements.
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