This arises out of a discussion with the ILFM.
Unfortunately, it’s not as straight forward in drawing up a list of what is and what isn’t material breach. Our view is that materiality can be very subjective and often left to interpretation.
To assist practices, they suggest you ask yourself the following questions in order to quantify if a breach is material or not;
If you are satisfied with your answers to all of the above questions, then it is likely to be viewed as a minor breach.
Some examples of what might lead to a qualified report;
We provide a remote monthly COFA & COLP Review service to several firms. Whilst we cannot be the Compliance Officers, we can help doing some of the spade work for them - providing a report for the COFA & COLP and highlighting issues that they should address. https://www.hunningsconsultancy.co.uk/colfa-colp-assistance/
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