SDLTM81600 - Compliance: Working an enquiry

Meetings: Preparation

Time spent preparing will be repaid once the meeting takes place. In the early stages of an enquiry the opening meeting should be viewed as an opportunity to establish facts and raise concerns with the purchaser face to face. If at all possible a compliance caseworker should not get drawn into a meeting for which they are not prepared.

If a purchaser arrives at the office unannounced, the compliance caseworker should try to arrange a time for a formal meeting, unless

  • the point to be discussed is relatively straightforward
  • it would be inconvenient for the purchaser to do so
  • it is not believed that the appointment will be kept

When examining records at the purchaser’s or agent’s premises, care should be taken not to be drawn into a discussion of other matters for which the compliance caseworker is not prepared and which will eat into the time available.

The extent of the preparation required depends upon the individual case, but a compliance caseworker should always

  • consider the purpose of the meeting
  • what do they want to know
  • why do they want to know it
  • what information do they need to address the risks identified and any concerns they may have
  • make notes to explain to the purchaser why they wanted the meeting
  • write down the questions they need to ask in the form of broad headings and detailed points
  • review thoroughly all the information held. They will have to react to what the purchaser tells them, which may contradict something which is in the papers. If a thorough review of the case was undertaken in the early stages, and it has been kept up to date since, this makes a review before a meeting much easier. Well ordered and indexed papers allow a compliance caseworker to refer to matters quickly and easily during the meeting
  • ensure they have agreed with their compliance manager the basis of settlement. In many cases it will become obvious during the course of the interview that omissions are sufficiently large and culpable for the enquiry to be extended. The middle of a productive meeting is not the time to break off to check and, if a compliance caseworker exceeds their discretion, this will cause embarrassment and delay