For agents, agencies, and individuals
What a compliance review actually looks at
A review is mostly a request for evidence. Agents who keep records experience it as paperwork; agents who do not experience it as a crisis.
The questions behind the request
What is a review trying to establish?
That the people recorded as your clients asked you to act for them, that you represented products accurately, and that you handled their information properly. Everything requested traces back to one of those three.
What will I be asked to produce?
Typically consent records, notes on what was discussed, and evidence for anything that looks unusual in the data, such as a cluster of similar applications or an address repeated across unrelated clients.
Does being reviewed mean I am suspected?
Not necessarily. Reviews include routine sampling. Treat it as a request for evidence and answer it factually rather than defensively.
What is the worst way to respond?
Late, partially, or with explanations instead of records. Reconstructing a file after the request has arrived looks exactly like what it is, even when the underlying work was honest.
Being ready before it arrives
What would a rehearsal look like?
Pick three clients at random and try to produce their consent, notes and decisions in ten minutes. Whatever you cannot find is exactly what a review would ask for.
Should I tell my agency?
Yes, immediately. Agencies have seen these before and can help you answer well. Handling it alone rarely improves the outcome.
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