CISI UK RPI — CISI UK Regulation & Professional Integrity Cheat Sheet

Cheat sheet for CISI UK Regulation & Professional Integrity (CISI UK RPI): UK regulators, FCA conduct, SMCR, market abuse, AML, complaints, and ethics.

Use the tables for a quick pre-exam check. Expand a topic’s notes for explanations, examples, and additional distinctions.

Scope and study context

Use this Cheat Sheet for the Chartered Institute for Securities & Investment exam CISI UK Regulation & Professional Integrity (CISI UK RPI) as a final consolidation pass before topic drills, mock exams, and detailed explanations.

This page is independent exam-prep support. It is designed to help you connect key UK regulatory concepts, professional integrity principles, and common scenario traps to independent companion practice, original practice questions, and question-bank review.

  1. Read the high-yield map first. Identify weak areas before opening a question bank.
  2. Review the decision rules. Many CISI UK RPI questions test “what should the firm or individual do next?” rather than pure definition recall.
  3. Use topic drills immediately after each section. Do not wait until you feel fully ready; original practice questions expose gaps quickly.
  4. Read detailed explanations carefully. For regulation questions, the explanation often matters more than the answer choice because similar facts can change the outcome.

Identity and exam-use focus

This independent Cheat Sheet supports candidates preparing for the Chartered Institute for Securities & Investment exam CISI UK Regulation & Professional Integrity with official exam code CISI UK RPI.

Use it to revise the practical distinctions the exam commonly tests: who regulates what, when FCA rules apply, how client protections differ, what must be escalated, and how professional integrity changes the correct answer.

AreaWhat to be able to do quickly
UK regulatory structureDistinguish FCA, PRA, Bank of England, HM Treasury, FOS, FSCS, and market infrastructure roles.
FSMA perimeterIdentify regulated activities, specified investments, authorisation needs, exemptions, and financial promotions.
FCA HandbookLink scenarios to PRIN, SYSC, COBS, CASS, MAR, COCON, FIT, DISP, COMP, SUP, DEPP, and related rules.
Conduct and clientsApply client categorisation, suitability, appropriateness, best execution, conflicts, and communications rules.
AccountabilityDistinguish Senior Managers, Certification staff, Conduct Rules, fit and proper standards, and regulatory notifications.
Financial crimeSpot AML, sanctions, bribery, fraud, terrorist financing, suspicious activity, and tipping-off issues.
Market abuseDistinguish insider dealing, unlawful disclosure, manipulation, inside information, and criminal/civil regimes.
Professional integrityChoose the answer that protects clients, markets, the firm, and the profession, not just the answer that is technically convenient.

UK regulatory map

BodyCore roleExam distinction
HM TreasurySets financial services policy and legislation framework.Policy maker, not the day-to-day conduct supervisor of firms.
ParliamentCreates primary legislation such as FSMA-based powers.Statute creates the legal perimeter; regulators make detailed rules within powers.
Bank of EnglandMonetary stability, financial stability, resolution, and oversight of key financial infrastructure.Think system-wide stability, not retail conduct.
Financial Policy Committee, or FPCMonitors and acts on systemic risk.Macroprudential focus: stability of the financial system as a whole.
Prudential Regulation Authority, or PRAPrudential regulation of banks, building societies, credit unions, insurers, and designated investment firms.Safety and soundness; dual-regulated firms also have FCA conduct supervision.
Financial Conduct Authority, or FCAConduct regulation, market integrity, consumer protection, competition, and prudential regulation of FCA-only firms.Main exam regulator for conduct, client treatment, market abuse, authorisation, and enforcement.
Payment Systems Regulator, or PSRRegulation of payment systems.Competition, access, innovation, and service-user interests in payment systems.
Financial Ombudsman Service, or FOSIndependent dispute resolution for eligible complaints.Resolves complaints; not a prudential regulator and not a compensation fund.
Financial Services Compensation Scheme, or FSCSLast-resort compensation when authorised firms cannot meet eligible claims.Compensates default/insolvency-type failures, not ordinary investment losses.
Information Commissioner’s Office, or ICOUK data protection regulator.Relevant for personal data, privacy, breach handling, and data subject rights.
Office of Financial Sanctions Implementation, or OFSIUK financial sanctions implementation and enforcement.Relevant to sanctions screening, asset freezes, and sanctions reporting.
Notes and examples

FCA versus PRA

ScenarioLikely regulator focus
Bank capital adequacy, liquidity, recovery planningPRA, with FCA conduct issues still possible.
Misleading investment promotion to retail clientsFCA.
Poor complaint handlingFCA rules and FOS process.
Market manipulation or insider dealingFCA and possible criminal authorities depending on facts.
Client money segregation failureFCA CASS.
Insurer solvency riskPRA prudential focus plus FCA conduct obligations.
Senior manager accountability in a dual-regulated bankFCA and/or PRA depending on function and issue.

UK regulatory architecture

The exam often tests whether you can identify the correct body, rule source, or route for escalation.

Body or frameworkCore role for exam purposesCandidate mistake to avoid
HM TreasuryGovernment department with responsibility for financial services policy and legislationTreating it as the day-to-day conduct supervisor
Bank of EnglandFinancial stability, monetary stability, and key market infrastructure responsibilitiesConfusing its macro role with individual retail complaint handling
Prudential Regulation AuthorityPrudential supervision of certain firms such as banks, insurers, and major investment firmsAssuming all investment firms are PRA-regulated
Financial Conduct AuthorityConduct regulation, market integrity, consumer protection, competition, and many firm authorisation/supervision functionsForgetting that conduct duties can apply even where prudential supervision is elsewhere
Financial Ombudsman ServiceIndependent complaint resolution for eligible complainantsConfusing complaint adjudication with compensation for firm failure
Financial Services Compensation SchemeCompensation scheme where authorised firms are unable, or likely unable, to meet claimsTreating it as the first step for every complaint
National Crime AgencyReceives suspicious activity reports through the UK financial crime frameworkConfusing external SAR reporting with internal escalation to the MLRO/nominated officer
FCA HandbookSource of many rules and guidance, including PRIN, SYSC, COBS, CASS, DISP, SUP, FIT, COND, DEPP and othersMemorising names without knowing what each sourcebook generally covers

Common FCA Handbook areas

AreaThink of it as…Typical exam angle
PRINHigh-level Principles for BusinessesBroad conduct failures
SYSCSenior management arrangements, systems and controlsGovernance, controls, compliance oversight
COBSConduct of business for investment businessClient communication, suitability, best execution, conflicts
CASSClient assets and client moneySegregation, custody, reconciliations
DISPComplaints handlingFinal response, escalation, Ombudsman rights
SUPSupervisionNotifications, regulator relationship
FITFitness and proprietyHonesty, competence, financial soundness
CONDThreshold conditionsMinimum standards for authorisation
DEPP / ENFDecision procedure and enforcementSanctions, disciplinary outcomes

FSMA perimeter and authorisation

General prohibition logic

Under the FSMA framework, a person generally must not carry on a regulated activity in the UK by way of business unless authorised or exempt. For exam questions, work through four tests.

TestAskWhy it matters
ActivityIs the person dealing, arranging, advising, managing, safeguarding, administering, accepting deposits, effecting insurance, or another regulated activity?If no regulated activity, FSMA authorisation may not be required, though other rules may still apply.
InvestmentDoes it involve a specified investment such as shares, debt securities, units in funds, derivatives, insurance contracts, deposits, or similar instruments?Regulated activity must usually relate to a specified investment.
Business elementIs it carried on by way of business rather than as a purely private one-off?The perimeter targets business activity.
UK connectionIs the activity carried on in the UK or sufficiently connected to the UK regime?Location and territorial scope matter.
Notes and examples

Common regulated activity traps

ActivityMeaning in exam scenariosTrap
Dealing as principalFirm buys/sells investments for its own account.Still regulated if done as a business activity in specified investments.
Dealing as agentFirm executes transactions for clients.Agency execution is not the same as giving advice.
ArrangingBringing about or making arrangements with a view to investment transactions.“I only introduced them” may still be arranging depending on facts.
Advising on investmentsPersonal recommendation on the merits of buying, selling, subscribing for, holding, or underwriting a specific investment.Generic education is different from a recommendation tailored to the person.
Managing investmentsDiscretionary management of assets belonging to another.Decision-making discretion is the key trigger.
Safeguarding/administeringCustody or administration of assets.CASS issues often arise once client assets are held or controlled.
Agreeing to carry on activitiesAgreement to perform a regulated activity can itself be caught.Do not wait for execution to identify the perimeter issue.

Authorised, exempt, appointed, approved

TermMeaningExam distinction
Authorised personFirm with permission from FCA and/or PRA.Authorisation belongs to the firm, not automatically to every employee.
Part 4A permissionPermission to carry on specified regulated activities.A firm must stay within its permission scope.
Exempt personPerson exempt from needing authorisation for particular activities.Exemptions are narrow and fact-specific.
Appointed representativePerson who conducts certain regulated activities under an authorised principal.Principal accepts regulatory responsibility for the appointed representative’s relevant activities.
Approved person / Senior Manager approvalIndividual approved to perform controlled or senior management functions.Individual approval is separate from firm authorisation.
Certified personIndividual performing a certification function, assessed as fit and proper by the firm.Certified by firm, not pre-approved by FCA for that function.

FCA Handbook high-yield map

Sourcebook / moduleWhat it coversTypical exam use
PRINFCA Principles for Businesses.Broad duties: integrity, skill, customers’ interests, communications, conflicts, regulators, Consumer Duty.
SYSCSenior management arrangements, systems, controls, compliance, risk, outsourcing.Governance failure, unclear responsibilities, weak controls.
CONDThreshold conditions for authorisation.Whether a firm remains suitable, resourced, supervised, and appropriately organised.
FITFit and proper test for individuals.Honesty, integrity, reputation, competence, capability, financial soundness.
COCONIndividual and senior manager Conduct Rules.Personal accountability and expected behaviour.
COBSConduct of Business Sourcebook.Client classification, communications, suitability, appropriateness, best execution, inducements.
CASSClient Assets Sourcebook.Client money, custody assets, segregation, reconciliations, records.
MARMarket conduct rules and guidance.Market abuse, disclosure standards, market integrity.
PRODProduct governance.Target market, product approval, distribution strategy, product review.
DISPComplaints handling and FOS rules.Complaint recognition, response, escalation, final response.
COMPFSCS compensation rules.Eligibility and compensation when firms fail.
SUPSupervision manual.Notifications, regulatory reporting, information gathering.
DEPPDecision Procedure and Penalties Manual.Enforcement process, penalties, notices.
EGEnforcement Guide.FCA approach to investigation and enforcement.
PERGPerimeter guidance.Whether activity is regulated.
TCTraining and competence.Competence, supervision, CPD, adviser standards.

FCA Principles and Consumer Duty

Principles for Businesses

No.PrincipleExam application
1IntegrityDo not mislead, conceal, backdate, misstate, or exploit information asymmetry.
2Skill, care and diligenceCompetent work, proper review, adequate evidence, and careful execution.
3Management and controlEffective governance, risk management, controls, oversight, and escalation.
4Financial prudenceMaintain appropriate financial resources and sound financial management.
5Market conductAct to preserve proper standards and market integrity.
6Customers’ interestsPay due regard to customer interests and treat them fairly.
7Communications with clientsCommunicate in a way that is fair, clear, and not misleading.
8Conflicts of interestManage conflicts fairly between firm/client and client/client.
9Customers: relationships of trustTake reasonable care to ensure suitability where discretion or advice applies.
10Clients’ assetsArrange adequate protection for client assets.
11Relations with regulatorsBe open and cooperative; disclose matters the regulator would reasonably expect notice of.
12Consumer DutyAct to deliver good outcomes for retail customers.
Notes and examples

Consumer Duty structure

ElementWhat it meansExam trigger
Consumer PrincipleA firm must act to deliver good outcomes for retail customers.Retail product or service design, sales, support, or communications.
Cross-cutting rule: good faithAct honestly, fairly, and consistently with reasonable customer expectations.Hidden charges, exploitative terms, misleading nudges.
Cross-cutting rule: avoid foreseeable harmIdentify and prevent harm a reasonable firm should anticipate.Known product risk, vulnerable customers, poor support journey.
Cross-cutting rule: support objectivesEnable customers to pursue financial objectives.Friction in cancellation, switching, claims, complaints, or accessing support.
Products and services outcomeProducts must be designed for an identified target market.Selling outside target market without justification.
Price and value outcomePrice should be reasonable relative to benefits.Fees not aligned with service or benefit.
Consumer understanding outcomeCommunications support informed decisions.Overly technical, unbalanced, or unclear disclosure.
Consumer support outcomeSupport should meet customer needs through the relationship.Long delays, obstructive servicing, inaccessible channels.

FCA Principles for Businesses

The Principles often provide the best answer in broad scenario questions.

Principle themeWhat it means in exam termsScenario clue
IntegrityAct honestly and fairlyConcealment, misleading statements, false records
Skill, care and diligenceCompetent, careful performancePoor review, careless recommendation, weak due diligence
Management and controlEffective organisation and risk controlsNo oversight, unclear responsibilities, weak compliance
Financial prudenceAdequate financial resourcesExcessive risk to firm stability
Market conductProper standards in marketsManipulation, disorderly trading, abusive behaviour
Customers’ interestsDue regard to customer interests and fair treatmentProduct sold for firm benefit over client need
Communications with clientsClear, fair and not misleadingUnbalanced risk/return claims
Conflicts of interestManage conflicts fairlyUndisclosed incentives, self-dealing
Customers: relationships of trustReasonable care where firm has discretion or client relies on itPortfolio management or advisory reliance
Clients’ assetsAdequate protection for client assetsPoor segregation, weak custody controls
Relations with regulatorsOpen and cooperativeDelayed notification, incomplete information
Consumer DutyDeliver good outcomes for retail customers where applicableProduct value, understanding, support, foreseeable harm

Consumer Duty quick review

For retail customer scenarios, check:

ElementPractical meaning
Act in good faithNo exploitation of customer behavioural biases or information gaps
Avoid foreseeable harmIdentify and reduce harm the firm could reasonably anticipate
Enable and support objectivesDo not create unnecessary barriers to customer outcomes
Products and servicesTarget market and product design must be appropriate
Price and valueCharges should be assessed against benefits and outcomes
Consumer understandingCommunications should support informed decisions
Consumer supportPost-sale service should not frustrate reasonable customer needs

Trap: Consumer Duty is not simply a slogan for “be nice to clients.” It is an outcomes-based standard, especially relevant to product design, distribution, communications, and support.

SMCR and individual accountability

Regime components

ComponentApplies toCore ideaExam clue
Senior Managers RegimeIndividuals performing Senior Management Functions.Regulator approval, clear responsibilities, reasonable steps.“Who is accountable?” “Statement of responsibilities?”
Certification RegimeIndividuals whose roles could cause significant harm to the firm or customers.Firm certifies fitness and propriety, usually at least annually.“Does FCA approve this person?” Often no: firm certifies.
Conduct RulesMost relevant staff, plus additional rules for senior managers.Minimum standards of individual conduct.“What should the employee do?”
Fit and proper assessmentSenior managers and certified staff.Honesty/integrity/reputation; competence/capability; financial soundness.Misconduct, lack of competence, financial distress, dishonesty.
Notes and examples

Individual Conduct Rules

RulePlain-English exam meaning
Act with integrityDo the right thing; do not deceive, conceal, or manipulate.
Act with due skill, care and diligenceWork competently and carefully; know limits of competence.
Be open and cooperative with regulatorsDo not obstruct; escalate and disclose appropriately.
Pay due regard to customer interests and treat them fairlyDo not prioritise sales, bonuses, or convenience over fair client treatment.
Observe proper standards of market conductNo market abuse, manipulation, improper information use, or misleading market behaviour.
Act to deliver good outcomes for retail customersConsider Consumer Duty where retail customers are affected.

Senior Manager Conduct Rules

Senior manager rulePractical expectation
Effective controlEnsure the business area is controlled effectively.
Compliance oversightTake reasonable steps to ensure regulatory compliance in the area of responsibility.
Proper delegationDelegate only to appropriate people and oversee delegated work.
Regulatory disclosureDisclose information the FCA or PRA would reasonably expect notice of.

Supervision, enforcement, and regulatory powers

FCA power / processMeaningExam use
Authorisation and permissionGrants or refuses permission to carry on regulated activities.Firm must have correct scope before activity begins.
Variation or cancellationChanges or removes permissions, including own-initiative action.Used where firm no longer meets standards or poses risk.
Information requirementRegulator can require documents, data, explanations.Not cooperating is a Principle 11 / Conduct Rule issue.
Skilled person reviewIndependent report into specified matters.Often used for systems, controls, remediation, or governance concerns.
InvestigationFormal inquiry into firm or individual conduct.Preserve evidence; cooperate; avoid tipping off where financial crime is involved.
Public censurePublic statement of misconduct.Reputational sanction without necessarily a financial penalty.
Financial penaltyMonetary sanction.Penalty may apply to firms and individuals.
Restitution / redressCompensation or repayment for harm caused.Customer detriment and remediation focus.
Prohibition orderPrevents an individual from performing regulated functions.Fitness and propriety failure.
Warning noticeProposed regulatory action.Early formal stage; subject can make representations.
Decision noticeRegulator decision after process.May be referred to tribunal where applicable.
Final noticeFinal published outcome.Confirms action, penalty, prohibition, or other outcome.

Client categorisation and conduct standards

Client categories

CategoryProtection levelTypical examplesExam trap
Retail clientHighestIndividuals and smaller clients not classified otherwise.Default category if no valid professional/ECP classification.
Professional clientReduced protectionsAuthorised firms, large undertakings, institutional investors, or clients validly opted up.Professional status does not remove all duties.
Eligible counterparty, or ECPLowest for eligible businessCertain financial institutions and sophisticated counterparties.ECP status applies only to certain activities and does not permit dishonesty or misleading communications.

Re-categorisation

MovementMeaningKey control
Retail to elective professionalClient opts up and firm assesses expertise, experience, and knowledge.Must follow proper process and warnings.
Professional to retailClient requests higher protection or firm treats as retail.More protections apply.
Professional to ECPOnly for eligible counterparty business and eligible clients.Cannot use ECP classification to avoid unsuitable retail treatment.
Notes and examples

Client categorisation

Client category affects the level of regulatory protection.

CategoryBroad meaningProtection levelExam reminder
Retail clientDefault highest-protection categoryHighestIf unsure, retail protection is usually the safer assumption
Professional clientHas experience, knowledge, and expertise to make investment decisions and assess risksLower than retailCan be per se or elective, but elective treatment requires process and warnings
Eligible counterpartyCertain sophisticated counterparties for eligible types of businessLowest for relevant businessNot a universal label for all interactions

Suitability, appropriateness, and execution-only

RouteWhen it appliesFirm must focus onCommon trap
SuitabilityPersonal recommendation or portfolio managementClient objectives, financial situation, ability to bear loss, knowledge and experience, risk toleranceTreating a product as suitable merely because it is “high quality”
AppropriatenessNon-advised sale of certain complex productsWhether client has knowledge and experience to understand risksConfusing it with full suitability
Execution-onlyClient gives order without advice, often for non-complex products where conditions are metClear process, no disguised advice, required disclosuresA helpful suggestion can accidentally become advice
Best executionExecuting client ordersBest possible result considering relevant execution factorsAssuming best price alone always decides
Product governanceDesigning and distributing productsTarget market, distribution strategy, reviewSelling outside target market without justification

Suitability red flags

A recommendation is vulnerable if:

  • The client’s investment objective is vague.
  • Risk tolerance is assumed from age or wealth alone.
  • Capacity for loss is ignored.
  • Costs and charges are not explained.
  • The firm recommends a product because it pays higher commission or benefits the firm.
  • The client does not understand leverage, illiquidity, concentration, or capital-at-risk features.
  • The adviser relies on old KYC information without checking material changes.

Advice, suitability, appropriateness, and execution-only

ConceptApplies whenRequired assessmentOutput / action
Information / guidanceGeneral facts, education, or explanation not tailored as a personal recommendation.Must still be fair, clear, and not misleading.Avoid implying a recommendation if none is intended.
Investment advicePersonal recommendation on a specific investment or action.Suitability: objectives, risk tolerance, knowledge, experience, financial situation, capacity for loss.Recommend only suitable actions; keep evidence and reports where required.
Discretionary managementFirm makes investment decisions for client.Suitability across mandate and transactions.Manage within mandate and risk profile.
AppropriatenessNon-advised business in complex products.Client knowledge and experience for the product/service.Warn if inappropriate or if insufficient information.
Execution-onlyClient instructs transaction without advice.For non-complex products at client initiative, appropriateness may not be required if conditions are met.Make clear no advice or assessment is being provided.
Notes and examples

Suitability versus appropriateness

IssueSuitabilityAppropriateness
TriggerAdvice or discretionary management.Non-advised complex product/service.
Looks at objectives?Yes.No, not normally.
Looks at financial situation and capacity for loss?Yes.No, not normally.
Looks at knowledge and experience?Yes.Yes.
ResultSuitable recommendation or decision.Product/service appropriate or warning required.
Common wrong answerTreating a complex execution-only trade as suitable because client asked for it.Performing full suitability when only appropriateness is required.

Communications, financial promotions, and inducements

Fair, clear, and not misleading

RequirementPractical meaning
BalancedDo not highlight benefits while hiding or minimising risks.
AccurateNo false, stale, or selective information.
UnderstandableAppropriate for target audience and product complexity.
Identifiable marketingMarketing material should be recognisable as such.
Risk disclosureProminent, relevant, and not contradicted by headline claims.
Performance informationNot cherry-picked; limitations and assumptions clear.
Notes and examples

Financial promotion restriction

PointExam application
What is caughtInvitation or inducement to engage in investment activity.
Who is caughtThe restriction can apply to unauthorised persons as well as authorised firms.
Lawful routeCommunicated by an authorised person, approved by an authorised person where permitted, or covered by an exemption.
MediaWebsites, social media, emails, calls, presentations, brochures, and oral statements can all be promotions.
Trap“It is only marketing” does not remove regulatory responsibility.

Inducements and conflicts

IssueCorrect handling
Fee, commission, gift, or hospitality from a third partyAssess conflict, client impact, disclosure, and whether it impairs duty to client.
Independent advice / portfolio management restrictionsBe alert to tighter limits on third-party benefits.
Soft commission / researchMust be controlled, justified, and not used to disguise improper benefits.
Sales targetsCannot override suitability, Consumer Duty, or fair treatment.
DisclosureUseful but not a substitute for preventing or properly managing a serious conflict.

Conflicts of interest and inducements

Conflicts are not automatically prohibited, but they must be identified, prevented, managed, and disclosed where appropriate.

Conflict typeExampleProper response
Firm versus clientFirm earns more from one product than anotherManage incentive, disclose where required, ensure suitable outcome
Client versus clientAllocation of limited investment opportunityFair allocation policy
Employee versus clientPersonal account dealing before client orderRestrictions, disclosure, monitoring, possible prohibition
Research / corporate finance conflictAnalyst pressure from issuer relationshipInformation barriers and independent controls
Gifts and hospitalityBenefit from a broker or issuerAssess materiality, record, approve, decline if improper

Decision rule: Disclosure alone is not a cure-all. If the conflict cannot be managed so the client is treated fairly, the firm may need to decline or stop acting.

Best execution and order handling

TopicRule of thumb
Core dutyTake all sufficient steps to obtain the best possible result for the client.
Execution factorsPrice, costs, speed, likelihood of execution and settlement, size, nature, and other relevant considerations.
Retail priorityTotal consideration, meaning price plus costs, is usually central.
Order execution policyFirm must establish, disclose as required, follow, and monitor it.
Client instructionsSpecific client instructions can limit the firm’s best execution obligation for that part of the order.
AggregationPermitted only with controls and fair allocation; cannot systematically disadvantage clients.
Timely executionExecute promptly, fairly, and sequentially unless conditions justify otherwise.
RecordsEvidence matters: venue choice, allocation, instructions, and monitoring.

CASS: client money and custody assets

ConceptMeaningKey controls
Client moneyMoney held for or on behalf of clients.Segregation, trust status, client bank accounts, reconciliations, prompt allocation and return.
Custody assetsDesignated investments held for clients.Proper registration, records, reconciliations, asset segregation, statements.
MandateFirm has authority over client assets or money without holding them.Control risk; keep mandate records and prevent misuse.
Title transfer collateral arrangement, or TTCAClient transfers full ownership to firm for collateral purposes.Not client money/assets once validly transferred; must be appropriate and documented.
Mixed remittancePayment contains client and firm money.Allocate promptly and treat client element correctly.
ShortfallRecords show less money/assets than owed to clients.Escalate, investigate, correct, and notify where required.
Notes and examples

CASS exam traps

TrapCorrect answer logic
“The firm is solvent, so segregation is less important.”Wrong. CASS protects clients especially if the firm fails.
“A nominee holds the assets, so the firm has no responsibility.”Wrong. The firm must maintain proper custody controls and oversight.
“Client money can be used temporarily for firm liquidity.”Wrong. Client money is not firm money.
“Reconciliation is a back-office admin issue only.”Wrong. It is a core client protection and systems/control issue.

Client money and client assets

Client asset protection is a common area for control-based questions.

ConceptQuick meaningExam trap
Client moneyMoney held for or on behalf of clients where client money rules applyAssuming all receipts are client money without checking capacity and arrangement
Custody assetsFinancial instruments held for clientsIgnoring records and ownership evidence
SegregationKeep client assets separate from firm assets“We can identify it later” is not adequate
ReconciliationCompare internal records to external recordsTreating reconciliation as optional admin
MandatesAuthority over client assets or accountsUnderestimating control risk
Title transfer collateralClient transfers full ownership to firm under arrangementMay not be treated as client money/assets in the same way
CASS oversightSenior accountability and controlsThinking custody is purely an operations issue

CASS-style decision rules

  • If the firm holds client money, ask whether it is segregated, recorded, and reconciled.
  • If the firm holds custody assets, ask whether ownership and location are clear.
  • If there is a shortfall, poor records, or commingling, the issue is not just operational; it is a client protection and regulatory issue.
  • If a third party is used, due skill, care, and diligence in selection and monitoring matter.

Product governance

RoleResponsibilities
ManufacturerIdentify target market, design product to meet target needs, assess risks, test product, set distribution strategy, review product performance.
DistributorUnderstand product, identify appropriate distribution market, follow distribution strategy, give feedback to manufacturer.
BothAvoid foreseeable harm, communicate clearly, monitor outcomes, act where product causes poor outcomes.
ScenarioLikely issue
Complex product sold to clients outside target marketProduct governance, suitability/appropriateness, Consumer Duty.
Charges make product poor valuePrice and value outcome.
Distributor does not understand product risksTraining, competence, PROD, COBS.
Product performs as designed but customers misunderstand riskConsumer understanding and communications.

Financial crime controls

AML and terrorist financing

ConceptMeaningExam action
PlacementCriminal proceeds enter the financial system.Watch for unusual cash, third-party funding, inconsistent source of funds.
LayeringTransactions obscure origin or ownership.Watch complex transfers, offshore structures, rapid movement.
IntegrationFunds appear legitimate.Watch asset purchases, investment liquidation, business proceeds.
Customer due diligence, or CDDIdentify and verify customer and beneficial owner; understand purpose and nature.Must be done before or during onboarding according to risk.
Ongoing monitoringReview transactions and relationship against expected profile.CDD is not a one-off exercise.
Enhanced due diligence, or EDDAdditional checks for higher-risk cases.PEPs, high-risk jurisdictions, complex structures, unusual transactions.
Simplified due diligence, or SDDReduced checks where lower risk and permitted.Not “no due diligence.”
Suspicious activity report, or SARReport suspicion internally and, where appropriate, externally.Suspicion is a low threshold; proof is not required.
MLRO / nominated officerReceives internal reports and decides external reporting.Staff should escalate, not investigate beyond role or alert client.
Tipping offImproperly alerting someone to a report or investigation.Do not tell the client a SAR has been or will be made.
Notes and examples

Sanctions

ControlPractical meaning
ScreeningCheck clients, beneficial owners, counterparties, and relevant payments against sanctions lists.
Asset freezeDo not make funds or economic resources available to sanctioned persons.
EscalationFreeze, reject/block where required, and report through proper channels.
False positivesInvestigate promptly and document rationale.
TrapAML comfort does not override sanctions. A low AML-risk client can still be sanctioned.

Bribery and corruption

Offence themeExample
Bribing another personOffering payment to win business improperly.
Being bribedAccepting benefit to act improperly.
Bribing a foreign public officialPayment or advantage to influence official function.
Corporate failure to prevent briberyOrganisation lacks adequate prevention procedures.
Gifts and hospitality testGood answer
Is it proportionate and legitimate?Modest, transparent business hospitality may be acceptable.
Could it influence behaviour?If yes, decline or escalate.
Is it recorded?Use gifts and hospitality register.
Is there a public official involved?Apply extra caution.
Would disclosure embarrass the firm or individual?If yes, likely inappropriate.

Financial crime

Financial crime questions reward disciplined escalation. Do not improvise, warn the customer, or investigate beyond your role.

Money laundering stages

StageMeaningExample
PlacementIntroducing criminal property into the financial systemCash deposit, initial investment
LayeringCreating complex transactions to obscure originTransfers across accounts or jurisdictions
IntegrationReturning funds as apparently legitimate wealthInvestment proceeds, property purchase

AML and CDD review

TopicQuick ruleScenario clue
Customer due diligenceIdentify and verify customer identityNew relationship, occasional transaction, doubt over identity
Beneficial ownershipIdentify who ultimately owns or controls the customerCompany, trust, nominee, complex structure
Risk-based approachHigher risk requires stronger controlsUnusual geography, structure, activity, or source of wealth
Enhanced due diligenceApply more scrutiny to higher-risk casesPEP, high-risk jurisdiction, unusual transaction pattern
Ongoing monitoringKeep information current and review transactionsActivity inconsistent with known profile
Record keepingMaintain evidence of checks and decisions“We knew the client personally” is not enough

Suspicion workflow

StepCorrect exam response
Red flag appearsPause and consider whether suspicion exists
Suspicion existsReport internally to the MLRO or nominated officer
Client asks questionsDo not tip off or disclose improper information
Transaction pendingFollow internal procedures and MLRO guidance
RecordsDocument facts, decisions, and escalation

Trap: “SAR” can mean suspicious activity report in AML and subject access request in data protection. Read the context carefully.

Other financial crime areas

AreaKey exam pointWrong instinct
SanctionsScreen clients, counterparties, and transactions; freeze or stop activity where requiredTreating sanctions as merely enhanced AML risk
BriberyImproper advantage, facilitation payments, gifts, hospitality, third-party agentsAssuming small payments are always acceptable
FraudDeception for gain or to cause lossWaiting for confirmed loss before escalating
Terrorist financingFunds may be legitimate or illegitimate; purpose is keyLooking only for criminal source of funds
Tax evasion facilitationFirm and employee controls matterTreating it as solely the client’s problem
Cyber-enabled crimeAccount takeover, payment diversion, identity compromiseProcessing urgent instructions without verification

Market abuse and insider dealing

Inside information

Inside information is generally information that is:

ElementMeaning
PreciseSpecific enough to draw a conclusion about possible price effect.
Non-publicNot generally available to the market.
Relates to issuer or financial instrumentDirectly or indirectly relevant to issuer, instrument, or related derivatives.
Price-sensitiveWould be likely to have a significant effect on price if made public.
Notes and examples

Market abuse behaviours

BehaviourMeaningExample
Insider dealingUsing inside information to deal or attempt to deal.Employee trades before unpublished takeover announcement.
Unlawful disclosureImproperly disclosing inside information.Banker tells friend about confidential transaction.
Market manipulationFalse or misleading signals, price distortion, deception, or abusive practices.Wash trades, spoofing, layering, ramping, misleading rumours.
DisseminationSpreading false or misleading information.Posting false takeover rumour to move price.
Benchmark manipulationManipulating input or process for benchmark setting.False submissions to influence benchmark rate.

Civil market abuse versus criminal insider dealing

PointCivil / regulatory market abuseCriminal insider dealing
FocusMarket integrity and administrative/regulatory sanctions.Criminal culpability.
ScopeBroad range of behaviours including manipulation and attempts.Dealing, encouraging, or disclosing inside information in criminal context.
Standard / outcomeFCA enforcement, penalties, prohibition, public censure.Criminal prosecution and potential criminal penalties.
Exam trap“No trade occurred” may still be attempted manipulation or unlawful disclosure.“I only encouraged someone else” can still be criminally relevant.

Market conduct controls

ControlPurpose
Insider listsTrack people with access to inside information.
Information barriersLimit flow of confidential/inside information.
Restricted listsPrevent or control trading in sensitive securities.
Personal account dealing rulesPrevent staff misuse of information and conflicts.
Market soundings controlsManage disclosure before transactions.
Suspicious transaction and order reportingEscalate suspicious market abuse indicators.
Clear disclosure proceduresEnsure issuers handle inside information properly.

Market integrity and market abuse

Market integrity questions often test whether behaviour damages confidence in fair, orderly, and transparent markets.

Inside information

Information is likely to be inside information if it is:

CriterionMeaning
PreciseSpecific enough to draw a conclusion about possible price effect
Non-publicNot generally available to the market
Relates to issuer or instrumentConcerns securities, issuers, derivatives, or relevant market matters
Price-sensitiveWould be likely to have a significant effect on price if public

Market abuse patterns

BehaviourWhat it looks likeTrap
Insider dealingTrading while in possession of inside informationProfit is not required for the behaviour to be problematic
Unlawful disclosurePassing inside information without proper reason“I only told one friend” is not a defence
ManipulationFalse or misleading signals, artificial price levels, abusive ordersCancelled orders can still matter
Rumour misuseSpreading false or misleading informationInformal channels are still communications
Benchmark or price distortionConduct designed to influence reference pricesThe market-wide effect is central
Improper order activityLayering, spoofing, wash trades, marking the close“No client complained” does not make it acceptable

Personal account dealing

If an employee wants to trade personally, ask:

  1. Does the employee hold inside or confidential information?
  2. Is there a pending client order?
  3. Is the trade restricted by the firm’s policy?
  4. Has pre-clearance been obtained where required?
  5. Could the trade create a conflict or appearance of impropriety?

If the answer creates doubt, the safe exam action is usually to escalate to compliance and do not trade until cleared.

Complaints, redress, and compensation

Complaint handling

StepWhat good handling looks like
Recognise complaintAny expression of dissatisfaction may be a complaint if it alleges or implies financial loss, distress, or inconvenience.
Acknowledge and investigatePrompt, fair, impartial investigation by competent staff.
Resolve quickly where possibleComplaints resolved by close of the third business day can use summary resolution communication where rules allow.
Final responseGenerally required within eight weeks, or explain delay and FOS rights.
Root cause analysisIdentify systemic issues, not just individual complaint outcome.
RecordsKeep complaint, investigation, outcome, redress, and communications evidence.
Notes and examples

FOS versus FSCS

BodyWhen usedWhat it does not do
Financial Ombudsman Service, or FOSCustomer has unresolved complaint against a firm and is eligible to refer.Does not compensate simply because investments fall in value.
Financial Services Compensation Scheme, or FSCSAuthorised firm is unable or likely unable to meet eligible claims.Does not replace normal complaint handling or cover every loss.

Redress logic

ScenarioLikely response
Unsuitable advice caused lossInvestigate, uphold if appropriate, calculate redress, remediate systems.
Poor service with inconvenienceApology, correction, possible compensation depending on facts.
Investment loss from normal market movementNot automatically compensable.
Firm failure with client assets missingCASS, insolvency, and FSCS eligibility may become relevant.

Data protection and confidentiality

Principle / dutyPractical meaning
Lawfulness, fairness, transparencyHave a valid basis and tell individuals how data is used.
Purpose limitationUse data only for specified legitimate purposes.
Data minimisationCollect only what is needed.
AccuracyKeep personal data accurate and up to date.
Storage limitationDo not keep data longer than needed.
SecurityProtect against unauthorised access, loss, or misuse.
AccountabilityBe able to evidence compliance.
ConfidentialityClient and firm confidential information must be used only for proper purposes.
Notes and examples
Data scenarioCorrect exam instinct
Client asks for personal dataRecognise data subject access process and verify identity.
Email sent to wrong recipientTreat as potential personal data breach; escalate and record.
Colleague wants client details for unrelated reasonDo not disclose without proper purpose and authority.
Regulator requests informationCooperate through correct internal process; consider legal privilege/confidentiality controls but do not obstruct.
Inside information is also personal/confidential dataBoth market abuse and confidentiality rules may apply.

Data protection, confidentiality, and records

AreaQuick review pointExam trap
ConfidentialityClient information should be protected unless disclosure is authorised or requiredSharing internally without need-to-know
Data protectionPersonal data must be processed lawfully, fairly, securely, and for proper purposesKeeping data indefinitely “just in case”
Data minimisationUse only what is neededCollecting excessive personal information
AccuracyKeep relevant records currentRelying on outdated KYC for advice
SecurityPrevent unauthorised access, loss, or misuseSending sensitive data through weak channels
Subject rightsIndividuals may have rights over their dataConfusing data access with AML SAR handling
Record keepingMaintain evidence of decisions, disclosures, checks, and approvalsAssuming verbal approval is enough

Governance, systems, controls, and outsourcing

AreaWhat the firm must evidence
GovernanceClear responsibility, oversight, reporting lines, challenge, and decision records.
Risk managementIdentification, assessment, mitigation, monitoring, and escalation of risks.
CompliancePolicies, monitoring, advice, breach handling, regulatory change management.
Internal auditIndependent assurance over controls where proportionate.
RecordkeepingEvidence of decisions, advice, transactions, communications, controls, and remediation.
Training and competenceStaff competent for roles, supervised until competent, ongoing CPD where required.
WhistleblowingSafe channels for raising concerns; no retaliation.
OutsourcingDue diligence, written agreement, monitoring, access/audit rights, exit plan, and retained responsibility.

Outsourcing trap

A firm can outsource an activity, but it cannot outsource regulatory responsibility. If a service provider fails, the regulated firm must still show it selected, contracted with, monitored, and controlled the provider appropriately.

Professional integrity

The CISI UK RPI exam does not test rules in isolation. It also tests whether you can apply the professional standards expected by the Chartered Institute for Securities & Investment and by regulators.

CISI Code of Conduct themes: exam-use summary

ThemePractical behaviourCommon wrong answer
Act honestly and fairlyPut client and market integrity ahead of personal gain.“Everyone does it” or “the client will never know.”
Act with integrityAvoid conduct damaging to the firm, profession, or public trust.Concealing errors to protect reputation.
Follow law, regulation, and standardsApply both letter and spirit of rules.Looking for loopholes to avoid fair outcomes.
Maintain market integrity and confidentialityDo not misuse information or distort markets.Trading on confidential information after hearing it informally.
Manage conflictsIdentify, avoid, control, disclose, and record conflicts.Disclosure only after conflict has already harmed client.
Maintain competenceKeep knowledge current and work within capability.Advising on unfamiliar products without support.
Decline work beyond competenceSeek assistance or refuse where not competent.Accepting work to please a client or manager.
Uphold high personal standardsBehave professionally inside and outside formal client interactions.Assuming private misconduct cannot affect fitness and propriety.
Notes and examples

Integrity decision checklist

When two answers both seem technically possible, choose the answer that best satisfies this sequence:

  1. Is it legal and within permission?
  2. Is it fair to the client or customer?
  3. Does it preserve market integrity?
  4. Does it avoid or properly manage conflicts?
  5. Would the FCA, PRA, employer, client, and public view it as transparent and honest?
  6. Is it within the individual’s competence and authority?
  7. Has it been escalated, recorded, and disclosed where required?

Professional integrity

Professional integrity is not separate from regulation; it is the behaviour that makes regulatory standards work.

Integrity decision framework

When a scenario feels ethical rather than technical, use this sequence:

  1. Identify the duty. Client interest, market integrity, confidentiality, legal obligation, employer policy, regulator duty.
  2. Identify the conflict. Personal benefit, firm revenue, client pressure, colleague pressure, time pressure.
  3. Avoid concealment. Do not hide facts, alter records, backdate documents, or create misleading impressions.
  4. Escalate properly. Compliance, line manager, MLRO, whistleblowing channel, or senior management as appropriate.
  5. Document. Record facts and decisions accurately.
  6. Do not act until cleared where the action could breach law, regulation, or firm policy.

Common professional integrity scenarios

ScenarioBetter answerPoor answer
Client asks you to ignore suitability informationRefuse to misstate facts; document and escalate if neededLet client sign a waiver for everything
Manager pressures you to approve misleading materialChallenge and escalateApprove because manager is responsible
You discover a trade allocation errorReport, correct fairly, assess client impactHide if no client notices
You receive confidential informationProtect it and use only for proper purposeShare with a colleague who is merely curious
You suspect money launderingFollow internal reporting; do not tip offAsk the client to explain in a way that alerts them
You made a mistakeDisclose internally promptly and support remediationDelay until you can fix records
A gift is offeredCheck policy, record, obtain approval or declineAccept if it does not obviously affect you

High-yield distinctions

DistinctionCorrect exam distinction
FCA vs PRAFCA is conduct and markets; PRA is prudential safety/soundness for PRA firms.
FOS vs FSCSFOS resolves complaints; FSCS compensates eligible claims when firms fail.
Authorised firm vs approved individualFirm permission is separate from individual approval or certification.
Senior Manager vs Certified staffSenior Managers need regulatory approval; certified staff are certified by firm as fit and proper.
Suitability vs appropriatenessSuitability is broader and applies to advice/discretionary management; appropriateness is narrower and applies to non-advised complex products.
Retail client vs professional clientRetail gets highest protection; professional has reduced protections but not no protections.
Professional client vs ECPECP is lowest protection and only for eligible counterparty business.
Advice vs informationAdvice is a personal recommendation; information is factual/general but must still be fair and clear.
Financial promotion vs advicePromotion induces investment activity; advice recommends a course of action. One communication can raise both issues.
Conflict disclosure vs conflict managementDisclosure alone is usually a last resort, not a complete control.
Client money vs firm moneyClient money must be protected and segregated; firm cannot use it for itself.
Market rumour vs inside informationRumour may be vague; precise non-public price-sensitive information can be inside information.
Suspicion vs proof in AMLSuspicion is enough to escalate; do not wait for proof.
Whistleblowing vs grievanceWhistleblowing concerns public interest wrongdoing; grievance is personal employment complaint.
Error correction vs concealmentCorrect, escalate, record, and remediate; do not hide.

Scenario triggers and likely answer direction

If the question says…Think…
“The client insists they understand the risk”Still assess suitability/appropriateness where required; client insistence is not a waiver.
“The product is profitable for the firm”Conflict, inducement, fair value, Consumer Duty.
“The information is confidential but not yet public”Inside information, confidentiality, information barriers, personal account dealing.
“A manager asks staff not to tell compliance”Integrity, escalation, whistleblowing, Conduct Rules, Principle 11.
“A client wants to invest unusually large funds from unclear source”AML, source of funds/wealth, EDD, SAR if suspicious.
“Client assets cannot be reconciled”CASS breach, operational risk, escalation, possible notification.
“The firm says the third-party outsourcer caused the issue”Firm retains regulatory responsibility.
“Marketing shows only high returns”Financial promotion and fair, clear, not misleading rules.
“A complaint is handled informally and not logged”DISP, recordkeeping, root cause analysis.
“A staff member is financially distressed”Fit and proper assessment, conflicts, fraud risk, supervision.
“A payment involves a sanctioned person”Freeze/block/escalate/report; sanctions override commercial pressure.
“A senior manager delegated the task”Was delegation appropriate and supervised? Reasonable steps matter.

Quick revision checklist

Rules and regulators

  • Know the difference between statute, regulator rules, guidance, and firm policy.
  • Map each scenario to the right body: FCA, PRA, Bank of England, FOS, FSCS, ICO, OFSI.
  • Apply the FSMA perimeter before assuming a firm can act.
  • Check firm permission scope, individual approval/certification, and competence.
Notes and examples

Client-facing conduct

  • Categorise the client correctly.
  • Decide whether the scenario is advice, discretionary management, appropriateness, or execution-only.
  • Apply fair, clear, and not misleading communications.
  • Identify conflicts early; do not rely on disclosure alone.
  • Apply Consumer Duty for retail customer outcomes.

Risk and escalation

  • Escalate AML suspicion, sanctions hits, market abuse indicators, CASS breaks, data breaches, and significant rule breaches.
  • Preserve records and evidence.
  • Cooperate with regulators through proper internal channels.
  • Do not conceal, backdate, mislead, tip off, or retaliate.

Professional integrity

  • Prefer answers that are transparent, fair, documented, competent, and escalated.
  • If a proposed action would look improper if reviewed by the FCA, client, employer, or court, it is probably not the best exam answer.
  • Rules are the minimum; professional integrity often requires a higher standard.

High-yield exam map

AreaWhat to know quicklyCommon trapPractice focus
UK regulatory structureFCA, PRA, Bank of England, HM Treasury, FOS, FSCS, NCA, firm responsibilitiesAssuming one body does everything“Who regulates / who handles / who compensates?” drills
AuthorisationFSMA general prohibition, permissions, regulated activities, exemptions, appointed representativesActivity is regulated only if both the activity and investment are specified and it is done by way of businessScenario classification questions
FCA principles and conductPrinciples for Businesses, conduct rules, Consumer Duty, client interests, conflictsPicking a narrow rule when a broad principle is clearly breachedPrinciple-to-scenario drills
Client categorisationRetail, professional, eligible counterparty; protection levelsTreating eligible counterparties as a universal category for all servicesCategorisation and disclosure questions
Advice and executionSuitability, appropriateness, execution-only, best executionConfusing suitability with appropriatenessAdvice-route decision questions
Market integrityInside information, market abuse, misleading behaviour, personal account dealingThinking a trade must succeed to be abusiveMarket abuse scenario drills
Financial crimeAML, CDD, EDD, sanctions, bribery, fraud, suspicious activity reportingTipping off, ignoring beneficial ownership, confusing sanctions with AMLRed-flag and escalation questions
Client assets and client moneySegregation, records, reconciliations, custody, client money controlsAssuming all money received by a firm is client moneyCASS-style concept drills
Complaints and redressInternal handling, FOS, FSCS, fair outcomesConfusing compensation schemes with complaint resolution“Where does the client go?” questions
Professional integrityHonesty, competence, confidentiality, escalation, conflicts, whistleblowingChoosing loyalty to employer over duty to clients, market integrity, or lawEthics scenario questions

Authorisation and regulated activities

A core CISI UK RPI skill is deciding whether a firm or person is permitted to do something.

The quick authorisation test

    flowchart TD
	    A[Proposed business activity] --> B{Is there a specified activity?}
	    B -- No --> Z[Likely outside regulated activity analysis]
	    B -- Yes --> C{Is there a specified investment?}
	    C -- No --> Z
	    C -- Yes --> D{Is it done by way of business?}
	    D -- No --> Z
	    D -- Yes --> E{Is the person authorised or exempt?}
	    E -- Yes --> F[Check permission scope and conduct rules]
	    E -- No --> G[Potential breach of general prohibition]
	    F --> H{Is there a financial promotion?}
	    H -- Yes --> I[Check approval or exemption and communication standards]
	    H -- No --> J[Apply relevant conduct, systems, and integrity duties]
Notes and examples

Key concepts

ConceptQuick review pointExam trap
General prohibitionA person must not carry on regulated activities in the UK unless authorised or exemptFocusing only on the product and ignoring the activity
Regulated activityExamples include dealing, arranging, advising, managing investments, safeguarding/administering assets, and other specified activitiesAssuming every financial conversation is regulated advice
Specified investmentThe investment must fall within the relevant statutory categoriesIgnoring whether the instrument itself is covered
By way of businessThe activity must have a business characterTreating a purely private, non-business action as automatically regulated
Part 4A permissionAuthorised firms need permission for the specific activities they conductAssuming authorisation for one activity permits all activities
Exempt personsSome persons may conduct certain activities without direct authorisation where an exemption appliesTreating exemption as unlimited permission
Appointed representativeActs under the responsibility of an authorised principal for permitted activitiesForgetting the principal’s oversight and responsibility
Financial promotionInvitation or inducement to engage in investment activity, communicated in the course of businessAssuming “marketing” is safe if no transaction has yet occurred

Financial promotion decision rules

A financial promotion question usually turns on four points:

  1. Is there an invitation or inducement?
  2. Is it communicated in the course of business?
  3. Is it approved by an authorised person or covered by an exemption?
  4. Is it fair, clear, and not misleading?

Common wrong answers:

  • “It is only a brochure, so rules do not apply.”
  • “The recipient is sophisticated, so no standards apply.”
  • “Risk warnings fix any misleading headline.”
  • “Past performance can be shown without balanced context.”

Complaints, redress, and regulator relations

Complaints

A complaint scenario usually asks whether the firm responds fairly and follows proper process.

IssueCorrect approach
Client expresses dissatisfactionRecognise possible complaint; do not dismiss because wording is informal
Complaint is validly receivedInvestigate impartially and promptly
Firm made an errorConsider redress, correction, and root-cause analysis
Client remains dissatisfiedProvide proper escalation information where applicable
Repeated complaintsIdentify systemic issues, not only individual cases
Notes and examples

FOS versus FSCS

RouteUse when…Not for…
Financial Ombudsman ServiceEligible complainant disputes firm’s handling or outcomeCompensating all losses from market movements
Financial Services Compensation SchemeAuthorised firm cannot, or is likely unable to, meet valid claimsRoutine service complaints against a solvent firm

Relations with regulators

Principle 11-style questions often turn on openness.

Regulated firms should:

  • Deal with regulators openly and cooperatively.
  • Notify regulators of significant matters where required.
  • Avoid misleading, incomplete, or delayed disclosures.
  • Maintain records that support regulatory reporting.
  • Escalate internally when a breach or potential breach is identified.

Trap: Hoping a problem “goes away” is rarely the correct answer. The exam usually favours early escalation, accurate records, and compliance involvement.

Senior management, conduct, and fitness

Fitness and propriety

ElementWhat it coversScenario clue
Honesty, integrity, reputationTruthfulness, ethical conduct, disciplinary historyFalse CV, concealed conflict, misleading regulator
Competence and capabilitySkills, qualifications, experience, trainingPerson lacks knowledge for role
Financial soundnessPersonal financial position where relevantSerious unmanaged financial problems

Conduct rule mindset

For individual accountability scenarios, ask:

  1. Did the person act with integrity?
  2. Did they exercise due skill, care, and diligence?
  3. Did they deal with regulators appropriately?
  4. Did they pay due regard to customer interests?
  5. Did they observe proper standards of market conduct?
  6. If they were a manager, did they take reasonable steps to control the business area?

Common mistake: Blaming “the firm” only. The exam may test both firm responsibility and individual accountability.

Fast scenario rules

Use this table when reviewing original practice questions.

If the question says…Think…
“The client insisted”Client pressure does not remove firm duties
“The employee did not personally profit”Integrity or market abuse can still be breached
“The information was only shared with one person”Confidentiality and unlawful disclosure still matter
“The firm is authorised”Check whether it has the right permission
“The client is wealthy”Wealth does not automatically mean professional client or suitable product
“The product has performed well historically”Past performance does not remove risk disclosure or suitability duties
“The adviser gave no formal recommendation”Substance matters; informal advice can still be advice
“The transaction is urgent”Urgency increases control risk; do not bypass AML or sanctions checks
“No complaint has been made”The firm may still need to correct harm or notify internally
“Everyone in the market does it”Market custom does not override law, rules, or integrity

Common candidate mistakes

  • Memorising regulator names but not understanding their responsibilities.
  • Confusing authorisation with permission for every activity.
  • Treating retail, professional, and eligible counterparty labels as interchangeable.
  • Choosing disclosure as the answer for every conflict, even where prevention or refusal is required.
  • Missing the difference between suitability and appropriateness.
  • Thinking AML concerns require proof rather than suspicion.
  • Forgetting that tipping off risk can arise after suspicion is reported.
  • Assuming market abuse requires profit, loss, or a completed trade.
  • Ignoring record keeping as a regulatory control.
  • Choosing commercial convenience over escalation, documentation, and client protection.

Short practice plan

For a focused final pass:

  1. Do 10–15 authorisation and financial promotion questions.
  2. Do 10 client categorisation, suitability, and conduct questions.
  3. Do 10 financial crime and market abuse questions.
  4. Do 5–10 professional integrity scenarios.
  5. Review every missed item using detailed explanations, then redo a mixed mini-mock.

Your next step: use the Cheat Sheet above to target weak areas, then practise with topic drills, mock exams, and a question bank of original practice questions with detailed explanations.

Put the review into practice

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