Compliance Consultant – Section 166

Section 166 reviews are one of the most powerful tools the FCA has to try to correct the actions of Financial Services organisations who they have concerns about. Section 166 gives the regulator the power to require a “skilled person” to carry out an independent review of a business.

An established Consumer Credit firm reached out to Kind Consultancy for support to help them work with the regulator following a Section 166 notice being issued.  The client had not worked with Kind before but were aware of our reputation for Interim Compliance resourcing. We met with their Head of Compliance and discussed the situation and their needs in detail – in their case the FCA had asked them to appoint the skilled person themselves.

We then providing them with one of an experienced Compliance Consultant from our Kind Agile Solutions bench, to work with the senior management team on the appointment of an FCA approved Skilled Person. We work with a number of Compliance SMEs and we knew this situation required someone who had previously completed Section 166 reviews, and also had experience of guiding a business through large scale remediation projects based on the recommendations arising from an S166.

The review required an assessment of more than 4,000 customers over a period of 5 years, so in addition to our Compliance Consultant, we also supplied a number of Compliance, Collections and Credit Risk professionals to complete the necessary appraisal in time.

We achieved the confidence of the FCA and a successful remediation project through detailed remediation methodology documentation, accurate and timely reporting, the demonstration of structured planning, and effective 3 lines of defence activity.