During discussions to establish WKM Wealth, most talks related to the client proposition, how much capital we would need to survive whilst our incomes ceased and what systems we were going to use. Having all worked in regulated roles for many years, but mainly as client facing advisers, the roles of compliance officer and money laundering reporting officer were secondary discussions.
After submitting what we felt was a good application to the FCA, it soon became apparent that getting these two roles right and ensuring the training and qualifications are in place to satisfy the FCA’s requirements and provide the right client outcomes and security, should be priority number one for any new firm looking to obtain direct authorisation.
Having sat on the board of a financial services business and acted as a training and competence supervisor, as well as pension transfer specialist, it was agreed I was best placed to fulfil the two important roles. As I didn’t have experience of either role, I was asked to attend a voluntary FCA interview to assess competency prior to us gaining approval.
Since our original application had gone in to the FCA, the team spent an enormous amount of time training and taking exams in the area of financial risk and financial crime as well as employing the services of a compliance consultant who provided a video call to prepare me for what was likely to be in store. Time was also well spent reading the FCA handbook and getting better accustomed to the layout and where the likely key queries were going to arise from.
My co-founder Ben Wattam attended with me and we made our way to Stratford, arriving in good time to have a coffee in sight of the FCA building and ready ourselves for the session ahead. Ben was allowed to be present but not contribute to answering questions. On arrival, we signed in and waited patiently for our case handler, who walked us to a private room where another senior team leader and an FCA legal team member were present.
The interview started with introductions for the tape to ensure any audio playback could identify who was speaking and then followed 45 minutes of intense questioning. A break was called at this point and after a quick stretch of the legs, matters continued along the same lines. In all, around 80 minutes were spent covering the areas the FCA wished to assess. It was a very intense and pressurised situation but one that looking back on I quite enjoyed.
For others who are required to attend an interview these are my top three tips:
- Prepare, prepare, prepare
- Don’t be afraid to admit if you don’t know something rather than waffle an answer
- Drink water and take your time in considering answers
After the interview Ben and I stopped off for a debrief and I asked him to be as honest as possible. His main observation was that I was ‘brutally honest about our journey’. Whilst this may have been a risky approach, in my view we had learnt a lot about what is required of a directly authorised business through our approval process and I wasn’t afraid to admit this and that I genuinely believe we will be a better firm as a result. Simply being compliant isn’t enough and we have to strive to be excellent and ensure client outcomes and experiences are the best they can be.
Hopefully if I ever have to visit the FCA offices again it will be in nicer circumstances, but it is certainly an experience that I am pleased I have had and taught me valuable lessons for the future.
Thanks for reading and