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What happens during an ICAEW DPB monitoring review?
Category: Compliance
An ICAEW DPB monitoring review is a routine inspection carried out by ICAEW's Professional Standards department. Its purpose is to check that your firm's investment business activity — including referrals to financial advisers — complies with the DPB Handbook and the ICAEW Code of Ethics. The review typically involves a visit to your firm (or a remote review) where an inspector will examine a sample of client files involving referral activity. They will look for evidence of informed client consent, proper fee disclosure, due diligence on receiving firms, record-keeping, and appropriate oversight within the firm. The inspector may also review your firm's referral policies and procedures, your panel of referral partners, and your systems for tracking referral outcomes. They will ask questions about how referrals are initiated, who approves them, and how fees are recorded and disclosed. Common issues found during reviews include: fees not disclosed to clients, consent obtained after the referral rather than before, no written records of referral activity, inadequate due diligence on partner firms, and blanket consent used where case-by-case consent is required. If issues are found, the inspector will make recommendations. In serious cases, this can lead to conditions being placed on your DPB licence, additional monitoring visits, or referral to ICAEW's Investigation Committee. The best preparation is to ensure your referral processes are documented, your records are complete, and you can demonstrate compliance for every referral in the sample period.