The latest edition of Market Watch sets out FCA’s concerns about how firms police PA dealing by staff. FCA has noted a number of common problems, such as:
- employees appearing not to understand their firms’ policy on PA dealing;
- firms and employees thinking that ignorance of policies is an acceptable mitigating factor for breach;
- employees deliberately not making required declarations and trading in breach of the policy;
- employees dealing against their own recommendations; and
- following and front-running client orders.
The newsletter contains a case study of bad practice, and FCA sets out what it expects firms, particularly in the wholesale markets, to do, to ensure they comply with the relevant rules in making their policies. It also stresses the importance of proper transaction reporting.