Executive summary . vii About the author . xi Chapter 1: The requirement to have a COLP and COFA Introduction to roles . 1 Brief background to the Legal Services Act 2007 . 1 Role of the SRA . 3 Key extracts from Standards and Regulations that explain the authorisation process for compliance officer role-holders . 5 Approval of role holders . 6 Approval process for individuals who are not deemed approved .

7 Individual role-holder and ongoing transparency requirements . 8 Withdrawal of approval . 12 Temporary emergency approval of a COLP or COFA. 12 Chapter 2: Appointing your COLP and COFA Key extracts from STaRs . 17 Compliance and business systems . 20 The duties of managers in SRA authorised firms . 22 Compliance officers - necessary skills, knowledge, experience Compliance officers - time factors and other considerations . 25 Specific considerations about the COFA role .

26 Can the COLP and COFA be the same person? . 27 Can we buy in a COLP or COFA? . 28 Chapter 3: Working with the SRA - understanding entity and risk-based regulation Regulatory objectives and a changed approach to regulation . 31 The impact of the LSA on the work of approved regulators . 31 The SRA''s approach to risk . 33 Regulatory reach over the authorised law firm . 34 The SRA''s supervision and enforcement work . 35 Investigation and enforcement .

35 What this style of regulation means for the COLP and the COFA . 36 Enforcement powers against the COLP and COFA . 36 Chapter 4: The COLP''s essential knowledge and suggested systems and controls The extent of the COLP''s responsibilities contrasted with the role of the COLP and the firm''s managers . 39 Key knowledge from the SRA Standards and Regulations of relevance to the COLP . 41 Overview of the STaRs from the COLP''s perspective . 42 SRA Principles . 43 SRA Codes of Conduct . 51 Chapter 5: The COFA''s essential knowledge and suggested systems and controls The extent of the COFA''s responsibilities contrasted with the role of the COLP and the role of the firm''s managers .

95 Key knowledge from the SRA Standards and Regulations of relevance to the COFA . 96 SRA Principles . 96 SRA Codes of Conduct . 99 SRA Accounts Rules . 101 Chapter 6: Identifying, recording, and reporting non-compliance How will compliance officers know what they need to know? . 126 Record-keeping . 127 File-based or central records? . 129 Centralised or decentralised record-keeping? .

129 Self-reporting by staff or file reviews and supervisory oversight? . 129 Just STaRs breaches or all complaints data? . 130 Records of decisions to deviate from the firm''s systems and controls . 130 What information should be included in the record? . 130 Identifying serious breaches - where to start . 131 The role of the management team in dealing with non-compliance issues . 131 Common breaches . 133 Chapter 7: Compliance officers and international issues Occasional or temporary practice outside England and Wales .

135 Firms with an "overseas practice" . 135 How to respond to this section of the SRA Standards and Regulations . 138 Other international regulatory issues . 139 Chapter 8: Behaviours outside of practice Equality issues outside of practice . 144 Chapter 9: Personal perspectives The relationship of the COLP and COFA with the management of the firm . 147 Is the role full-time or part-time?. 147 Should the role be held for a fixed period? . 148 Should there be a deputy or understudy? .

148 Remuneration . 149 When and how often the compliance officer should report to the management team . 149 How will compliance officers work with the management team? . 150 Insurance and indemnity . 151 Sources of help . 152 About Globe Law and Business . 153.