Answer
Guidance note (iii) to Rule 8 of the SRA Authorisation Rules 2011 indicates that the SRA expects firms to have such a plan. The note mentions a firm's compliance plan and gives the following examples of what may be included:
- Clearly defined governance arrangements providing a transparent framework for responsibilities within the firm
- Appropriate accounting procedures
- A system for ensuring that only the appropriate people authorise payments from client account
- A system for ensuring that undertakings are given only when intended, and compliance with them is monitored and enforced
- Appropriate checks on new staff or contractors
- A system for ensuring that basic regulatory deadlines are not missed e.g. submission of the firm's accountant's report, arranging indemnity cover, renewal of practising certificates and registrations, renewal of all lawyers' licences to practise and provision of regulatory information
- A system for monitoring, reviewing and managing risks
- Ensuring that issues of conduct are given appropriate weight in decisions the firm takes, whether on client matters or firm-based issues such as funding
- File reviews
- Appropriate systems for supporting the development and training of staff
- Obtaining the necessary approvals of managers, owners and COLP/COFA
- Arrangements to ensure that any duties to clients and others are fully met even when staff are absent
For more information, please see the SRA Authorisation Rules 2011.
For further support on risk management and regulatory compliance covering this and other areas, you may wish to consider joining the Law Society's Risk and Compliance Service.
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