The survey was carried out in response to the fact that the FSA sent a “Dear Compliance Officer” letter across the industry this June, causing mixed reactions as to whether the regulator had got the target addressee right. The letter concerned the inappropriate marketing of unregulated investment schemes to retail investors and gave compliance officers only just over a month to respond.

Of those surveyed, 34 per cent said they disagreed when asked if the compliance officer is the right person to address such queries to; a further 26 per cent said they disagreed strongly. Meanwhile, 32 per cent agreed that the CEO is the one who should be addressed in such letters, and a further 42 per cent said they strongly agreed with this statement.

The CISI’s Compliance Professional Interest Forum has in fact raised this issue with the FSA, in a missive which said: “This particular letter in our view identified the wrong person and is a precedent to be avoided in the future. The FSA has consistently observed that failings in firms often stem from a failure of culture – and specifically, of compliance culture – at board and senior management level. Consequently we were surprised that this letter was not addressed to an executive board member such as the CEO, but to the compliance officer.”

The CISI’s Compliance Professional Interest Forum is concerned that the FSA seems to think that compliance officers are more senior than they tend to be. “Even when the holder of CF10 is indeed a board member (and our experience is that this will often not be the case), the executive director with whom most responsibility and influence rests will always be the CEO. Therefore we were surprised that this letter did not continue the established practice and address itself to the CEO,” said Julian Sampson, chairman of the Forum.

The Forum also took issue with the timescale the FSA’s June letter imposed; within five weeks compliance officers were requested to compile detailed answers to questions covering four years of historic data. When asked if they thought that the timescale of the letter was appropriate, 39 per cent said they disagreed and 39 per cent disagreed strongly.