Just before Fridays Webinar we had our attention drawn to a seeming contradiction between 2010 CDS Contract and SQM.
The former does not now contain mandatory frequency, volume and method requirements for File Reviews (save for staff working at unsupervised branch offices).
The latter repeats the old Contract requirement – minimum 2 per month, quarterly and 50% face-to-face).
Now I like the 2010 CDS Contract Specification A 2.14 & 15 but I also like SQM E2.1 (a) – but which one is better? There is only one way to find out
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The contract is a floor below which you cannot fall, and it is consistent with the lexcel requirement, and also perfectly compliant with the new OFR requirements. In many instances of course the contract will require reviews far in excess of SQM. But if you choose SQM over lexcel then there is a theoretical risk that for some people there will be more file reviews than are necessary. I say theoretical as it is difficult in my view to imagine many instances where the SQM minimum would be sufficient. It is a minimum, not a guide to what is would be required in most cases. To pass on the FR criteria, and I think Simon would agree that if you fail on FR then you fail full stop, you must demonstrate a dynamic supervision and file review policy. People looking to transaction based compliance will I feel be in for a nasty shock. That’s my two-penneth.