
Data subject access requests
Practical guidance for financial services firms responding to data subject access requests, including deadlines, redaction and supplementary information.
Browse all articles across people aspects of regulation and people development within UK financial services

Practical guidance for financial services firms responding to data subject access requests, including deadlines, redaction and supplementary information.

Our industry is very good at creating acronyms. The Financial Conduct Authority has given us a new one, Non-Financial Misconduct (NFM).

Following the FCA’s announcement in December 2026 of the removal of minimum annual CPD requirement, many firms are reassessing what training and competence should look like in practice. This article explores the potential impact on approaches to T&C, and how CPD can be used to drive competence, value and better outcomes in 2026 and beyond.

In this Q&A session, we dive into a topic that affects every financial services firm: Training & Competence (T&C). And since it’s that time of year, we’re asking the question: Is your T&C scheme on the ‘Naughty or Nice List’? To help us explore this, we have a true industry veteran, Jeff Abbott.

Is my T&C Scheme on the naughty list? It’s that time of year when letters are winging their way to you know who asking for all sorts of gifts in exchange for promising to stay on the ‘nice’ list. Extending the ‘naughty or nice’ theme please indulge us for just a couple of minutes.

The Senior Managers and Certification Regime (SMCR) has been with us since December 2016 for larger firms and December 2019 for firms regulated by the FCA alone. The SM&CR is an individual accountability regime.

John Griffith Chaney died at the age of forty. Better known in literary circles as Jack London, he was a novelist, journalist, and activist, and one of the first American authors to become an international celebrity, earning a large fortune from his writing.

What am I talking about? In this instance, I’m referring to assessing training needs and evaluating the effectiveness of the delivered training on a group basis. The FCA guidance within the TC Sourcebook states that firms should assess the training needs of their staff at the outset and regular intervals.

The Fit and Proper test for Employees and Senior Personnel sourcebook, or FIT is in the High Level Standards block of the FCA Handbook.

In the client facing area of financial services, there is a school of thought, that you recruit those that already have the right knowledge and the required external training and qualifications, so that they can fit into the business quickly, rather than undergoing a longer, unproductive, period of internal training.

In February 2024, the FCA wrote to a number of financial advisory firms requesting information about their delivery of ongoing services for which their clients continue to be charged after advice has been given.

In a previous article, we looked at the FCA’s focus on fair value and how regulated firms should invest in training to highlight the value they add within the distribution chain. However, in our work auditing the robustness of T&C schemes, we are finding that many firms are still not getting this right.