Section 166 Skilled Person Review Preparation Toolkit

When the FCA exercises its Section 166 power, your firm faces one of the most significant regulatory interventions short of formal enforcement. The difference between a well-managed review and a costly, prolonged process often comes down to preparation.

This toolkit gives you everything you need to prepare for, manage, and respond to a Section 166 Skilled Person Review – from the moment you receive the FCA's notice through to post-review remediation and ongoing monitoring.

What's Inside:

Understanding Section 166 Reviews – A clear, practical explanation of the legal framework, the FCA's approach, types of reviews, and your firm's rights and obligations under FSMA 2000.

Pre-Review Preparation Framework – A structured protocol covering your first 24 hours, 48 hours, and first week response. Includes a comprehensive Governance Readiness Assessment matrix, Document Readiness Checklist covering 20+ core regulatory documents, Systems and Controls Review guide, and Staff Preparation guidance.

Skilled Person Selection and Appointment – Selection Criteria Assessment Matrix with weighted scoring, Terms of Reference Review Guide, and Cost Estimation and Budgeting framework to help you exercise meaningful influence over the appointment process.

Project Management Framework – Complete internal team structure with role descriptions aligned to SMCR functions, a 7-phase project timeline and milestone tracker, communication protocols, and information management and security procedures.

Information Request Management – A structured process for managing information requests with a tracking log template and quality assurance checklist for every submission.

Gap Analysis and Self-Assessment Tool – A comprehensive RAG-rated self-assessment covering Governance and Senior Management, Financial Crime Controls, and Consumer Duty and Conduct, with structured remediation prioritisation.

Stakeholder Communication Templates – Ready-to-adapt Board Notification Template, Staff Communication Template, and FCA Communication Guide with practical drafting guidance.

During the Review – Operational Guide – Practical guidance on managing on-site visits, preparing staff for interviews (before, during, and after), real-time issue management, and progress monitoring.

Post-Review Action Planning – Findings Analysis Framework, Remediation Action Plan Template, Board Reporting Template with 8-point structure, Regulatory Response Guide, and Ongoing Monitoring Framework.

Cost Management Guide – Cost Tracking Template covering all major cost categories, and practical guidance on challenging unreasonable costs.

Common Pitfalls and Best Practice – The top 10 mistakes firms make during Section 166 reviews with best practice alternatives, drawn from real regulatory experience.

Regulatory Reference Guide – Key legislation, FCA Handbook references, FCA guidance, and industry guidance sources.

Appendices with Ready-to-Use Templates – Master Pre-Review Checklist (20 items), Key Contacts Register, and 16-Week Review Timeline Planner.

Who This Toolkit Is For:

This toolkit is designed for compliance officers, MLROs, senior managers holding SMF roles, risk managers, in-house legal counsel, and compliance consultants advising FCA-regulated firms that are facing or anticipating a Section 166 Skilled Person Review.

Why This Toolkit:

• Built from practical regulatory experience, not academic theory
• Every template is ready to use and adapt to your firm's specific circumstances
• Covers the complete lifecycle from initial notification to post-review monitoring
• Aligned to current FCA expectations and FSMA 2000 requirements
• Helps demonstrate the cooperation and professionalism that regulators expect
• Designed to minimise disruption and help you achieve the best possible outcome
• Format: Microsoft Word (.docx) – fully editable and customisable.

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