The New Year is a great opportunity to start fresh on the kinds of projects that are hard to sustain: behaviour-change projects. The most important of which is compliance behaviour throughout the business. 

Most companies start with a basic approach which could be summed up as 'what do I need to check?' or 'what do I need to get the client to sign?' it is solely focused on disclosure, getting the right forms filled in – a box-ticking exercise. Unfortunately, most companies never get beyond this. 

A better approach is to design processes for compliance – redesigning the sales process so that necessary disclosures are seamlessly included, rather than obviously 'bolted-on'. This looks and feels better for adviser and client alike. After five years a number of advice businesses have done this. If there is a change to the FAA it will need to be done again. 

Still better than this is to add good management processes. There are two tracks, an operational one, in which compliance process observance and outcomes are monitored and reported through day-to-day activity: sales reports, management, and line management. The other track is a separate governance one which audits the normal operations. This is about sampling to check that operational procedures are being carried out. It is also principles-based and reviews compliance with the spirit, not just the letter, of the rules.

Finally, there is the culture of compliance. This is the part which is above and beyond the duty of a company to meet rules, it is usually led by non-executive directors, engagement with consumer advocates, and contemplates the requirements of consumers your business may not currently serve, or may not serve well. At this point the culture of enhancing consumer outcomes is frequently an engine of growth. 

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