How to Navigate the Skilled Person Review

This presentation explains the Skilled Person Review (Section 166) process and its importance in FCA supervision. It outlines when reviews are triggered, what firms can expect, and how to prepare effectively. Learn practical strategies for managing compliance risks and discover how MEMA Consultants supports firms with guidance, oversight, and tailored compliance solutions. For more details visit: https://www.memaconsultants.com/insights-blog-posts/how-to-navigate-the-skilled-person-review

1. How to Navigate the
Skilled Person Review

A brief guide on what to do when your firm is required
to appoint a Skilled Person by the regulator (FCA).

2. Understanding the Skilled Person Review
Supervisory Tool
The s166 Skilled Person
Report is a supervisory tool
under s166 of FSMA.
FCA Authority
Gives the FCA power to require
any regulated firm to provide a
report by a Skilled Person.
Firm Pays
The FCA commissions the report,
but the regulated firm concerned
pays for the Skilled Person's work.

3. Role of the Skilled Person
The Skilled Person provides the required resources and
necessary expertise to review areas of concern
identified within a firm.
They assess the effectiveness of remedial action a firm
has taken, ensuring compliance and risk mitigation.

4. Two Types of Review
S166 Skilled Persons Report
A comprehensive report on any matter
reasonably required by the FCA in connection
with its regulatory functions under the Act.
S166A: Skilled Person Information
Exercise
A focused exercise to gather specific
information as requested by the regulator.
Firms normally nominate the Skilled Person, but the FCA must formally approve the appointment.

5. To identify, assess, and measure risks within
the firm.
Diagnostic
When the FCA Commissions a Review
The Skilled Person Review is used for four primary regulatory purposes:
To track the development and evolution of
identified risks.
Monitoring
To limit or reduce identified risks before
they crystallize or increase.
Preventative Action
To respond effectively to risks once they have
already crystallized.
Remedial Action

6. Key Triggers for a Review
Estimated costs and timescales are
proportionate to the regulatory risk
being mitigated.
The FCA requires an independent opinion
to support a view or theory it holds.
A Skilled Person Review is used when the FCA requires an independent opinion or lacks
internal resources.
The regulatory risk requires timely
intervention, and the firm needs independent
support for rectification.
The FCA does not have the appropriate level
of internal resources to conduct the review.
Proportionality
Independent Opinion
Timely Intervention
Resource Constraints

7. Preparation and Support
If you have questions on the Skilled Person process or
what steps to take, reach out to expert teams for guidance.
We have also released a guide on Preparing for
an FCA visit to help you adequately prepare your
team for regulatory visits.

8. Secure Solutions for a Regulated World
Bridging Compliance and
Business Excellence
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Contact us for expert support in areas like Consumer Credit, Payment Services, and the Senior
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