From a Multi-Module Rule Change to One Clear Plan

The DFSA publishes a notice that amends several Rulebook modules at once. Some changes to prudential reporting take effect almost straight away. Others, on Islamic finance and conduct, take effect a few months later.

Harbourlight's compliance team is small and already busy. It has to work out which parts apply to a Category 3C fund manager with an Islamic window, which returns, policies and marketing materials are affected, and how to show the board that the firm acted in time.

1. Before Day 1

   Firm Profile

   We record Harbourlight's licence category, permitted activities, the Islamic window and its three funds. No client data is needed.

2. Day 1

   Monitor and Filter

   The notice is logged the day it is published. We flag the changes that touch a Category 3C fund manager with an Islamic window and set the rest aside, with a one-line reason each.

3. Days 2 to 3

   Map to the Firm

   Each relevant change is traced to Harbourlight's own documents: the prudential returns it files, its Shari'a systems and controls policy, and its fund marketing.

4. Day 3

   Summarise and Recommend

   One note per change, in our own words: does it apply and why, impact, effective date, and the actions with a suggested owner and due date.

5. Day 4

   Human Review

   A person checks each note against the source before it is sent.

6. Ongoing

   Track to Closure

   Each action stays open in the change log until the firm marks it done, with the evidence attached.

• Two Impact Notes

  One on prudential returns (high impact, act now) and one on the Islamic finance changes (medium impact, before the effective date).

• An Action Plan

  Six actions, each with an owner and a due date: finance maps the returns, compliance reviews marketing, the policy is updated.

• A One-Page Board Summary

  What changed, what applies, what the firm is doing and by when, ready for the next board meeting.

• Change Log Entries

  Each change recorded, including those that do not apply, with the evidence to keep for each.

• A Clear Answer, Early

  The firm knows soon after publication what applies and what does not, without reading each publication in full itself.

• A Plan the Team Can Run

  Actions are assigned and dated, so the work can start straight away instead of waiting on interpretation.

• Board and Supervisor Ready

  The board sees a short summary and a documented decision. The change log shows the review if the DFSA asks.

• Time Back for Compliance

  The team spends its time on the changes that matter to the firm, not on reading everything that is published.