Skilled Persons Review (S.166)


Huntswood is appointed to the FCA’s Skilled Person panel for ‘Lot B’ (Governance and Individual Accountability) and ‘Lot D’ (Conduct of Business) and are approved to undertake Skilled Persons Reviews on behalf of the regulator.

A Skilled Persons Review is one of the supervisory tools the FCA has at its disposal under Section 166 (S.166) of the Financial Services and Markets Act (2000). It is an independent review of a regulated firm, usually focusing on specific issues, or where the regulator wishes to delve deeper into a firm’s activities. A Skilled Persons Report is the typical deliverable of such a review, and will establish the extent of any problems and / or the degree of any customer detriment or remediation required.

While it is the FCA that commissions the report, they will nominate, or ask a firm to nominate (with the agreement of the FCA), a Skilled Person to undertake the work.

It’s important to select the right firm to undertake the review because the report and recommendations provided by the Skilled Person will also help the FCA to determine:

  • The extent of any remedial action that needs to be undertaken
  • The ongoing supervisory relationship the firm has with the FCA
  • Whether enforcement action should be taken against the firm

Huntswood helps firms who are the recipients of s.166 draft notices to scope and undertake a review that meets the FCA’s specifications. Huntswood’s closeness to regulatory issues and its dialogue with the FCA means that our experts can help firms re-establish the regulator’s trust through tripartite communication in the event of a review.

 We help firms to:

  • Ensure open interaction with the regulator, demonstrating the firms’ willingness to cooperate with the terms of the review
  • Quickly discern the extent of any issue, and collaboratively devise a proportionate methodology for remediation (implementing this following agreement from the regulator)
  • Gain assurance over their preparedness for a review. This can be as part of a wider regulatory health check, or in isolation, and can include mock FCA interviews to really illustrate what a firm may encounter.


Why Huntswood

Significant, demonstrable experience of undertaking Skilled Persons Reviews

Facilitating tripartite communication with the regulator to fully understand its concerns and communicate the firm’s methodology for solving any confirmed issues