“A firm must have robust governance arrangements, which include[s] a clear organisational structure…”                                                                                                                                                                                                                                                                                                        Senior Management Arrangements, Systems and Controls (“SYSC”), rule 4.1.1, UK Financial Conduct Authority (“FCA”) Handbook

What do a chief of staff refining his firm’s reporting lines, a senior compliance analyst writing a report to her senior management and an account executive pruning an application to a firm’s credit committee all have in common? Answer: they all need an effective structure to articulate their objectives. Assessments are no different.

A.C.Culley & Co.’s CEO and founder, Alexander Culley, has used the following structure to successfully tackle academic and professional assessments for over 20 years:

• Point
• Evidence
• Comment

How it works

• Decide what point(s) you need to make in your article or exam paper. For example, in a 2,000-word assignment there might be six core points that you have to cover. Allocate roughly 250 words to addressing each of these points, leaving enough room to pen an introduction and conclusion. Be careful to maintain balance between the points. Spending excessive time (word wise) addressing one or two points conveys a message to the examiner that these are more important than the others. This is unlikely to be persuasive. Furthermore, if writing an article in exam conditions, adopting this strategy will help ensure that you do not get side-tracked and run out of time. You will always receive more credit for dealing with more points succinctly and convincingly than you would for labouring a single point.

• Select the most relevant (and, if possible, latest) example available to reinforce your point. If you are writing an article in coursework (remote) conditions, then take full advantage of the “Insert Citation” functionality that is found in “References” tab of Microsoft Word. This will make your life so much easier. Enabling the systematic management of sources as you go, this is more efficient than trying to compile references after you have finished writing. You can also create a bibliography automatically using the source list that you have assembled.

• Reflect on the significance of the point and the supporting evidence in the context of the overall question that you have been asked to answer. This is critical. Refer to the assessment question again. What is it asking you to do? “Analyse”, “assess”, “discuss” and “examine” are examples of words that are typically deployed in assessment questions. For example, if the question is asking you to “assess” something, then make sure you do this at the comment stage. For a good explanation of assessment terminology, it’s worth taking a trip down memory lane and visiting BBC Bitesize: https://www.bbc.co.uk/bitesize/guides/zqd9j6f/revision/1

Worked example

Mock question: Explain the role of the principal of an appointed representative (“AR”).

You identify six points: the performance of due diligence prior to appointment, entering into a suitable agreement, notification to the FCA, implementation of systems and controls to supervise the AR, management of training and competence, and ongoing monitoring.

Our worked example provides a possible structure for considering the last point concerning ongoing monitoring.

• Point: Lastly, the principal must monitor the activities of its AR. The level of monitoring should be proportionate to the level of risk posed by the AR’s activities, something which a principal should assess prior to appointment. Consummate with the size, scale, nature, and complexity of those activities, the principal must dedicate adequate resources to monitoring the AR’s compliance with the agreement and applicable regulations (SYSC 12.4.2R(3), SUP 12.6.11A). Should the monitoring reveal serious evidence of non-compliance, the principal may need to consider terminating the agreement.

• Evidence: The importance of a principal conducting proper monitoring of its ARs’ activities is illustrated by the findings of Thematic Review 16/6 (“TR 16/6”). Focused on the use of ARs in the general insurance sector, the FCA found significant weaknesses in the supervision of ARs by principal firms. Firms were found not to have detected mis-selling, something which had led to significant consumer harm in one instance. Accordingly, the FCA mandated section 166 reviews and the cessation of sales at two firms. Furthermore, the FCA imposed restrictions on several firms’ permissions to prevent them from engaging any new ARs.

• Comment: As demonstrated by the fallout from TR16/6, a principal’s failure to effectively monitor the activities of their ARs can have serious consequences. This exemplifies why a principal should only utilise ARs if it can commit to investing sufficient intellectual, financial and temporal capital to fulfilling their responsibility to ensure robust ongoing oversight. The alternative: reputational damage, threat of disciplinary action and, worst of all, prejudice to the interests of customers, is likely to prove far more expensive for the principal firm.

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A.C.Culley & Co. also offers a mentoring service to aspiring senior managers. This covers preparation for examinations, interviews with regulators (as part of the process for seeking approval) and understanding obligations under, for example, the Senior Managers and Certification (“SMCR”) regime. Please contact enquiries@acculley.com for more information about this service.