Recommendation 1 – Fostering industry role in gatekeeping – the review recommends that the CBI ought to provide greater clarity and guidance to industry on the role of regulated entities in the gatekeeping phase to ensure that they understand what is expected of them. This will encourage a proactive approach by the regulated entities in the F&P process.
Recommendation 2 – Clear fitness and probity standards – standards ought to be accessible and consolidated in a single location. They must be comprehensive, enhanced and regularly reviewed.
Recommendation 3 – Governance – the establishment of an F&P gatekeeping unit with responsibility for the entire gatekeeping process, enhanced implementation of a risk-based approach for F&P gatekeeping, a reconsideration of the overall number of PCF roles and adjustment in approach to different sectors.
Recommendation 4 – Decision-making – the establishment of a significant decisions committee with a Chair who is a senior official not routinely involved in the assessment stage.
Recommendation 5 – Communication and IT platform – the CBI to organise an annual information session for firms and individuals to assist with their understanding of the F&P process. Ad hoc workshops to be organised to obtain feedback from firms to improve efficiency in the process.
Recommendation 6 – Interview stage – notification of a minimum of five working days for interviews which should last no longer than 90 minutes. Interview environments should be conversational rather than adversarial. Individuals permitted to bring a note keeper or a lawyer as observers. The CBI to provide feedback in all cases.
Recommendation 7 – Efficiency of interview process – “meet and greet” type interviews should not form part of the F&P gatekeeping process. The CBI should aim to conduct one single comprehensive interview.
Recommendation 8 – Withdrawals/feedback – interview feedback to be provided in cases where withdrawal occurs and that the CBI will not engage in off-record discussions with regulated entities regarding specific F&P applications.
Recommendation 9 – Management information – the CBI should provide clear and comprehensive service standards, commit to time limits (e.g. 90 days for F&P gatekeeping applications), report various data and qualitative points in order to promote transparency and avoid confusion.
Recommendation 10 – Quality assurance – a robust quality assurance mechanisms should be set in place with an externally appointed risk advisor.
Recommendation 11 – Complaints procedure – a complaints procedure should be established specifically for the F&P gatekeeping process and led by an externally appointed risk advisor.
Recommendation 12 – Training – develop a comprehensive training programme for the F&P gatekeeping process.
