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Glossary

Triggered review

A triggered review is an extra review of an AR, covering the same ground as the annual review, that the principal must carry out when one of the events named in SUP 12.6A.3R happens. It is in addition to the annual cycle and is recorded in the same way.

The five triggers in the rule

  • The AR changes its business model, including its target market.
  • The AR's scope of appointment is expanded to one or more additional regulated activities.
  • The AR changes any of its senior management in a particular role with responsibility for the activities in scope more than once in 12 months.
  • The AR is appointed by an additional principal.
  • The principal identifies a significant increase in the number of complaints about the AR.

Alongside the review

  • Separately, the principal should reassess its controls and resources on rapid growth, unusual staff turnover, rising complaints, a change of business model or any change to the scope of appointment (SUP 12.4.4FG).
  • Triggered reviews are recorded (SUP 12.6A.4R), feed the self-assessment, and do not apply to IARs.

Common misconceptions

“There are four triggers.”
The FCA's guidance page lists four and leaves out the senior management trigger. The rule has five.
“Any scope change triggers a review.”
Only an expansion to additional regulated activities does. A narrowing still prompts a reassessment of controls under SUP 12.4.4FG.
““Significant increase in complaints” has a set threshold.”
The Handbook gives no number. The principal has to define it and evidence how it applies it.

In Merrin

Merrin's monitors watch for the triggers, such as a new principal on the Register or a rise in complaints, and raise an issue that can start a triggered review.

Monitoring & issues

Sources

Checked against these sources on . This is general information, not legal advice.

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