Principle 11 requires a firm to deal with the Financial Conduct Authority (FCA) in an open and cooperative way and to disclose appropriately anything related to the firm that would reasonably be expected to be reported.
This includes notifying the FCA of any ‘significant’ failure of systems or controls or ‘significant’ breach of a rule. ‘Significant’ should be determined by the potential financial loss to customers or to the firm, frequency of the breach, implications on the firm’s systems and controls and if there were delays in identifying or rectifying the breach. For example, if the firm conducted a review of internal procedures/files and significant levels of unsuitable advice or failings were identified, they should be reported to the FCA immediately.
