The NACFB has a new training and education programme which has now been established for a few months, so we can see how enthusiastically it is being taken up by our members. One thing we have had to bear in mind when preparing a set of exams for members is that the topics have to be very carefully judged. Too specific, and individual brokers will say the exams are not appropriate for them; too vaguely-defined, and nobody learns anything. This is partly why everyone’s used to taking qualifications in Anti Money Laundering, the three-word subject in which nobody really knows where you’re supposed to put the hyphen. (It’s not about laundering anti-money, is it?)
There are plenty of titles which will relate more closely to the day-job of each member. It will mean that everyone can choose to remain focused on whatever they are experts on, while sharing the same set of basic competences.
What’s particularly helpful about our system is the way it doesn’t just tell you what you got wrong (or, even worse, just a straight “Pass/Fail” grade), but revisits each question where you missed the right answer and explains it with a “reason why” box. The course then recommends further reading on the area that it has identified as being one that you have found challenging. A score of 100% means more if you’re not scoring it on a second run with the answers neatly written down on the back of a business-card.
We’re also ten per cent of the way through visiting all our members, to give them confidence that, if the next knock at the door is made by the knuckles of the FCA, they will be fully prepared to deal with that meeting. The challenge faced by our members in proving they are fully compliant is very different from – but perhaps no more onerous than – the challenge facing the NACFB in calculating how best to get to all 861 member firms within 450 days, as we’d already promised our members that this would be done before the end of 2017.
But the idea is that if we do it, we can demonstrate to the FCA that they won’t need to.
At the conclusion of each visit our member will receive a personalised action plan so that he or she can be confident about what extra things need doing to meet the highest standards. For example, we may ask to see an introducer record or a complaints log. There’s no implication that the absence of these constitutes any kind of malpractice, of course, and we anticipate some challenges along the lines of: “I haven’t got x, but I have got y and it’s more or less the same thing.”
Where we can offer particular value is where we’ve spoken to the FCA and we understand how they would rule on various points of contention, so the broker doesn’t need to be second-guessing a large, arm’s-length organisation.
When the NACFB is reaching out to SMEs around the country, we’re very pleased to see how well spread out our brokers are, from Penzance to Peterhead. It’s when we actually have to go and knock on their doors that we find ourselves wishing they all lived in the same village – Ettington in Warwickshire, for example, which has about the same population as our membership. I would recommend they all move there, if it weren’t for the need for us to look truly National.
The clock is already counting down the twelve months we have allocated for this exercise…so no one will have to wait very long.
Adam Tyler, Chief Executive Officer, NACFB