The recent update to the Core Practice Management Standards (CPMS) requires CQS firms to have a policy in place in relation to conflict handling (s5.7).
Policy documents can be time-consuming and difficult to prepare.
The Conflict Handling Policy includes reference to:
Assessment of circumstances
Acting for lender and borrower
Referrals giving rise to potential conflicts of interest
Action to be taken where there is a conflict
...as well as other formalities and general obligations as required under 5.7 of the CPMS.