Historically, while we have accelerated visits as needed to respond to risk, we’ve predominantly operated on the following cycles for IP monitoring visits:
- a one-year cycle for volume individual voluntary arrangement (IVA) providers;
- a six-year cycle for IPs at most of the large and mid-tier firms; and
- a three-year cycle for all other IPs.
Visit cycle criteria
In the early part of 2024 we moved to a more varied risk-focused cycle for most IPs. We have begun using a six-year baseline, unless any of the following factors indicate a higher risk, in which case your visit will be brought forward:
- the outcome of your previous visit;
- your disciplinary record/complaints history;
- the size and mix of your portfolio;
- any adverse publicity;
- your involvement in any high-profile cases; and/or
- other intelligence, including your responses to our annual return and information provided by other regulators.
For new IPs, we consider our regulatory experience of your firm and monitor your caseload through your cover schedules. The latest date for your first visit will be three years from the date of your first appointment (lead or non-lead), but it’s likely to be considerably earlier.
Those IPs that meet the volume IVA definition will remain on a one-year review cycle.
Cashiering
We have also refreshed our cashiering work. While we have always covered cashiering on our full reviews, in future the level of cashiering work we carry out will depend on the perceived risk. That, in turn, will depend on factors such as:
- whether cashiering issues arose during your previous monitoring visit or were raised in your most recent insolvency compliance review;
- whether your firm is an ICAEW member firm, or subject to a Practice Assurance contract, and whether any clients’ money issues arose on your firm’s most recent Practice Assurance visit;
- the quality of your latest annual SIP 11 review – and whether it included sample testing; and/or
- the level of estate funds you’re holding.
During 2024 we will be carrying out bespoke cashiering reviews at the larger and mid-tier firms with ICAEW-licensed IPs.
Resources
Access our compliance review guidance which includes a checklist to help you carry out a better SIP 11 review.
