QAD's SIP tips
In 2017, over 40% of all findings raised on QAD’s visits related to non-compliance with one or more of the SIPs. The main culprits were SIP 9 and SIP 16 but there were also some other common areas, such as SIP 1.
In March 2018, Claire Harsley and Victoria Alexandrou, insolvency reviewers in ICAEW’s Quality Assurance Department (QAD), presented a webinar on the recurring SIP issues that QAD sees on its visits to insolvency practitioners (IPs). In this article, Allison Broad revisits some of the headlines from this presentation in relation to SIPs 1 and 9.
The key issue we are seeing with SIP 1 relates to compliance with the requirement to disclose that IPs are bound by the insolvency code of ethics. The SIP requires this to be included in your first communication to creditors. We have seen this overlooked completely on some visits, or on certain case types on others; usually those types to which the IP is appointed less frequently. One way you can ensure you’re compliant is to add a statement to that effect to your footer. Including a link to the code of ethics on your letterhead is helpful but on its own doesn’t meet the requirement, because you need to specifically explain that you are bound by the code.