Corterum charges clients by reference to the number of ‘active persons’ about whom regulatory information is saved. In Corterum parlance, ‘active persons’ are known as active “Person Entities”.
One of the over-arching principles of our business is to make a powerful SM&CR solution available to the ENTIRE industry. We want firms of all sizes to have access to a dedicated solution to assist with the effective management of their SM&CR compliance – not just those which have the deepest pockets and the largest resources. We have tried to align our charging structure with this over-arching principle.
To this end, we have tried to create a charging structure that represents good value for money for companies of all sizes, whilst excluding none. Broadly, this adopts the approach of ‘the more you use, the more you pay’. However, we are aware that there are certain aspects which are specific to SM&CR that potentially impact on this approach. For example, firms which are subject to the SM&CR are required to maintain information about ex-employees for up to six years for the purposes of being able to respond to a request for a regulatory reference. We felt that it would not be fair to charge clients for such ‘non-active’ users. As such, we concluded that the fairest overall approach would be only to charge for ‘active persons’ about whom regulatory information is saved within the system.
The table below helps to explain the circumstances in which a charge will or will not be made with respect to different types of ‘users’ of the Corterum platform.
If you have any further questions, please contact us at [email protected]
Staff member description | Chargeable? | Explanation |
Current Senior Manager, current Certification Employee or current Conduct Rules Staff | Yes | This person would require a “User Account” in order to access the Corterum system AND would require a “Person Entity” to be created (as regulatory information would be stored about the individual). |
Administrative user who is NOT subject to the SM&CR (e.g. “Ancillary Staff”) | No | This person would require a “User Account” in order to access the Corterum system but would NOT require a “Person Entity” to be created (as no regulatory information would be stored about that individual). |
Administrative user who IS subject to the SM&CR (e.g. Head of Compliance) | Yes | This person would require a “User Account” in order to access the Corterum system AND would require a “Person Entity” to be created (as regulatory information would be stored about that individual). |
Staff member working for an Appointed Representative | Yes | This person may or may not require a “User Account” in order to access the Corterum system (depending on the preferences of the directly authorised entity) BUT would require a “Person Entity” to be created (as regulatory information would be stored about that individual). |
Ex-employee (information retained for compliance purposes / for the purposes of responding to a Regulatory Reference) | No | This person would NOT require a “User Account” as access to the Corterum system is no longer required. A “Person Entity” is required (as regulatory information would be stored about that individual). However, no charge would be levied as regulatory data is no longer ‘actively’ being stored with respect to that individual. |