Total Compliance

I had a robust, face-to-face exchange with a “Commissionaire” recently and was a bit surprised by the detail on some of the points made – especially re Proof of Means.

I have in front of me an audit outcome which, by contract, is both pleasing and confusing in equal measure. Pleasing because we have won some points and some money back for clients, and it demonstrates sensible application of discretion. Confusing, well because it is. There is certainly a disconnect somewhere at the LSC, which certainly makes my point for me, the guidance should be completely re-written. On the other hand it helps nobody that sober consideration of the matter occurs right at the end of the assessment process and not earlier on.

Entirely expectedly a near identical case, to one in the appeal, has arisen within minutes of an office discussion on the subject. This is a file from a sample we are verifying for the self same CM. What to do?

Then whilst typing this post we get an e-mail from a firm just this minute through a CM visit which is described a “Zero Tolerance”*. This approach was taken despite an admission that some were “borderline”.

We will continue to encourage “Total Compliance”.

*(I am forbidden from using my term for this on the blog)

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