The Legal Services Act 2007 requires every firm to appoint a Compliance Officer for Finance and Administration (COFA). The COFA has a more focused role than a COLP (Compliance Officer for Legal Practice) and has two key responsibilities:

• to ensure compliance with the SRA's accounts rules
• to record all failures to comply and to report any such failures to the SRA as soon as is reasonably practicable.

This toolkit provides practical assistance to the COFA to implement and oversee systems for compliance in relation to the Accounts Rules and includes:

• payment authorisation forms
• draft undertakings
• reporting and monitoring forms
• development and training policy
• draft letters and reports.

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Contents

1. 1. Introduction
2. 2. Principal regulatory requirements of COFAs
3. 3. Becoming a COFA
4. 4. Responsibilities of the COFA
5. 5. Reporting requirements
6. 6. Further guidance.
7.  
8. Appendices (contained on CD):
9. Overall compliance checklist for COFAs
10. Terms of appointment to the role of COFA
11. Temporary emergency notification letter to the SRA
12. SRA guidelines- accounting procedures and systems checklist
13. Guidance on matter file reviews
14. Matter file review template
15. Pro forma templates for the recording of breaches internally
16. Template letter for reporting material breaches to the SRA
17. Common areas of breaches of the Accounts Rules
18. Internal policy for dealing with mixed payments
19. Framework for monitoring, reviewing and managing risks of non-compliance
20. Examples of key general controls expected to be in place in law firms.

About the Author

Jeremy Black is a Partner in Deloitte’s professional practices group.