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The Authority has also taken into account the following factors which mitigate the seriousness of failings:
2 (a) voluntarily and proactively assisted its customers in obtaining redress as soon as it became aware that Keydata had been placed into administration, including attempting to obtain ex gratia payments for customers from its professional indemnity insurers
(b) helped to set up and fund at its own expense a group to fund legal action in the USA to recover assets for investors in the and
(c) has taken extensive action to improve its advisory and record keeping processes including: introducing an Investment Committee to review investment policy, providers and products and use of proprietary research tools replacing its back office systems introducing a new operations manual, fact finds and procedures for assessing customers’ ATR recruiting an experienced Compliance Officer and assisting its advisers to obtain additional professional qualifications.. “the Act” means the Financial Services and Markets Act 2000 “the Authority” means the body corporate previously known as the Financial Services Authority and renamed on 1 April 2013 as the Financial Conduct Authority “ATR” means attitude to risk or the degree of risk that a customer is willing to accept in connection with the purchase of an investment product “COB” means the Conduct of Business Sourcebook, which formed part of the Authority’s Handbook and was in force until 31 October 2007 “COBS” means the Conduct of Business Sourcebook, which forms part of the Authority’s Handbook and has been in force from 1 November 2007 “combined relevant period” means the period of time consisting of the first relevant period and the second relevant period “DEPP” means the Authority’s Decision Procedure and Penalties manual, in force from 28 August 2007 “EG” means the Authority’s Enforcement Guide, in force from 28 August 2007 “ENF” means the Authority’s Enforcement manual, i
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