FCA Skilled Person Reviews (s166)

Baringa is an FCA/PRA section 166 (s166) panellist and has undertaken a wide variety of reviews over recent years (FCA and PRA lists). We are experts in Financial Crime, Client Assets (CASS) and Risk and Controls Frameworks. More recently our reviews have extended to include consumer protection, outcomes, and mis-selling, all of which is pertinent to the FCA’s Consumer Duty.

If your firm has received a s166 requirements notice or you are concerned that you may be facing a s166, it is worth getting in touch with Baringa to discuss potential options.

How we can help you

• Baringa as your section 166 Skilled Person – finding the right person for this is essential and you should always speak with more than one nominated Skilled Person. We listen to your needs, are honest if we feel we are not right for you and will recommend any other areas where we feel more support could be helpful.
• Shadow reviews – getting a second opinion from a firm that knows what regulators look for is a sensible move in many cases. Typically, we are engaged before the end of key phases to provide challenge prior to the regulator’s review to give you peace of mind.
• Remediation support – sometimes the firm that was the original Skilled Person cannot support remediation or additional specialist technical expertise may be required. We work collaboratively with you and your other advisors to support as necessary.
• Advice on specific matters - with a wide market perspective many firms select us because of our senior specialist teams who are able to give practical advice on important technical matters.
• Support pre s166 – we can work with you to get ahead of the game and any issues and can help advise on how best to communicate with your regulator to keep them informed.
• Supporting you directly – where another firm is acting as the Skilled Person (maybe appointed directly by the FCA) we can guide you through the process.
• Redress and back book review – we can help identify customer detriment and any case for redress.

Baringa is a global business, and we also have experience of similar regimes in other countries, e.g. Consent Orders and MRAs.

What it’s like to work with Baringa

• We aim to work with you the Baringa way. We make sure that there are no surprises in our final reports and that our clients are part of the process with plenty of opportunity to discuss and input into the review.
• We provide technical expertise combined with a broad market view. With new areas coming into focus such as Consumer Duty, ESG and greenwashing, the latest technical knowledge and market experience is critical.
• We are independent but also aim to bring our market context to be fair and reasonable.
• Each situation is unique and we do not provide ‘cookie cutter’ support or responses.

If you are worried your firm might be at risk of receiving a s166 requirements notice, then please do get in touch with one of our experts today to have an informal discussion about your options.