Central Bank of Ireland – Industry Letter Following Thematic Reviews

Thu May 30 2024

29th May 2024

Dear Member,

 We are aware that the Central Bank has today issued a letter to intermediaries following their thematic Review of Compliance with the Minimum Competency Code and the Consumer Protection Code.

Brokers Ireland held a meeting with the Central Bank to discuss the contents of the letter last week as we were concerned that the letter was drafted in a manner to convey an impression that the review was comprehensive, but there is no evidence to support this.  We sought clarification as to how many inspections were carried out and the break down between small, medium and large firms and how firms were selected, but the Central Bank refused to provide this information.  Brokers Ireland is concerned that some of the selected firms may already have had flagged compliance issues and therefore the sample was skewed and tarnishes the majority of Brokers who strive to operate in a compliant way.

While the letter acknowledges many good practices, they are minimised by comparison with the strong language used in the letter around the weaknesses.

 We note that the Central Bank has requested all Retail Intermediaries to:

“Review their business practices and compliance arrangements against the findings, expectations and good practices set out above and in Schedule 1. This review and its outcomes must be documented. This should include details of actions taken to address findings, with reference to updated procedures, processes, controls, registers, templates and training, as well as timelines for implementation. This review should be completed, and an action plan discussed, approved and evidenced by the firm’s management team by 31 August 2024. The Central Bank expects that this document will be available for review during future engagements with any Retail Intermediary”

 The 31 August 2024 is the date by which the review is to be completed and an action plan documented and agreed by senior management. Implementation of the action plan can take place post-31 August and within a reasonable timeline set out by each firm.

 Brokers Ireland will provide further guidance in relation to the letter in due course.

Kind Regards

Diarmuid Kelly

CEO

Brokers Ireland 

 


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