Regulatory and Compliance Training & Consultancy

COLP and COFA Nomination Timetable Update

20 April 2012

Speaking at a conference yesterday, Samantha Barrass, SRA Executive Director, announced the SRA‘s revised plans for nominating and appointing Compliance Officers for Legal Practice (COLP’s) and Compliance Officers for Financial Administration (COFA's).

Ms Barrass told the audience that firms would be able to nominate COLPs and COFAs from 31 May 2012, with a closing date of 31 July. Ms Barrass explained that the launch of the COFA/COLP nomination form has been delayed to take account of the late start of the PC renewals and recognitions exercise, giving the SRA more time to ensure firms did not experience difficulties with the nominations process.

Firms will be asked to complete a web-based nomination form. The form that firms will be asked to complete will be short but based on binding declarations by both a senior manager with authority to sign on behalf of the firm and the COLP and COFA nominees, for which the signatories will personally be held to account by the SRA. There will also be declarations relating to the Suitability Test.

The form will include:

• confirmation that the firm has suitable arrangements in place to ensure that the COLP and COFA are able to discharge their duties, and
• confirmation that the nominees for the COLP and COFA roles have sufficient seniority and responsibility in the firm, and
• confirmation that the declarations made by COLP and COFA nominees are complete and accurate.

The SRA will take a risk-based approach to checking nominations, but will go back to a subset of firms largely on a risk basis. It will also conduct some random sampling. Dedicated phone support will be available to firm managers and nominees seeking advice. COLP‘s and COFA’s in Alternative Business Structures will still be subject to a full series of checks to ensure that they work to the same high standards as traditional law firms