Review and remediation generally aim to place affected clients in the position they would have been in if misconduct or other compliance failures had not occurred.
Fiduciam applies the principles of Regulatory Guide 256 and in developing a review and remediation program we recognise that:
- implementation may differ between the various types of review and remediation; and
- licensees may need to consider specific legislative requirements or other guidance that applies.
Key considerations for licensees include:
- when to initiate the process of review and remediation;
- the scope of review and remediation;
- designing and implementing a comprehensive and effective process for review and remediation;
- communicating effectively with clients; and
- ensuring access to external review.