COBS 4—Systems, controls and records
COBS 4—Systems, controls and records

The following Financial Services guidance note provides comprehensive and up to date legal information covering:

  • COBS 4—Systems, controls and records
  • Financial promotions: systems and controls
  • Financial promotions: useful considerations
  • Financial promotions: keeping records

This Practice Note explains the Financial Conduct Authority (FCA)'s rules on systems, controls and records in relation to financial promotions (contained in the Conduct of Business sourcebook (COBS) at COBS 4.10 and 4.11).

Financial promotions: systems and controls

Firms who issue financial promotions are required to put in place systems and controls or policies and procedures in order to comply with the rules in COBS 4. Firms also need adequate systems and controls to ensure that their non-promotional communications are compliant, and in particular that they are fair, clear and not misleading.

Chapters 3 and 4 of the FCA's Senior Management Arrangements, Systems and Controls sourcebook (SYSC) set out the high-level requirements for these systems and controls.

There is considerable flexibility for firms when deciding how best to meet these requirements for their own circumstances. What is appropriate in the circumstances will differ from firm to firm, product to product and from communication to communication.

The following questions are worth considering:

  1. are people w