The challenges you face
Consumer needs are now more than ever at the heart of the Regulator's business plan 2016/17, putting focus on the governance and culture of the firm. Firms need to demonstrate that it has the interest of its customers and the integrity of the market at the heart of how the business is run. Firms are required to have governance and risk management in place to ensure that the decision-making processes and implementation of decisions by senior management and the board are effective and keep pace with new regulations and stakeholder expectations.
Senior management sets the tone and the culture of the organisation, shaping judgements, ethics and behaviours that matter to the performance and reputation of firms, and the service that it provides to customers and clients. Firms need to imbed an effective culture that supports its business model, and inherent within that, the fair treatment of customers.
Individual accountability of Directors and Senior Managers is increasing. Individuals carry increasing personal risk and may feel that they lack experience, confidence or knowledge to feel properly equipped to represent the firm. In addition, regulatory requirements and expectations continuously change, and so it is difficult for individuals to have confidence that the right risks are being managed.
What we offer
Our Financial Regulation team has an integrated Regulatory Risk and Compliance Practice Group with Compliance Professionals that specialise in governance, risk and compliance which is focused in supporting firms with the FCA systems and control challenges.
Ensuring your firm has in place a clear, understandable system of governance, which covers all areas relevant to the decisions your firm needs to make, will assist the firm in gaining confidence with its regulators.
We offer a wide range of services which can be tailored to specific client needs and requirements, including:
- Health Check and Effectiveness Review – review of theoretic governance arrangements and more detailed 'on the ground' assessments of governance arrangements in practice;
- Management Information Review – with a view to making systems of governance more effective and efficient, potentially by simplifying structures, processes and documentation, and cutting down unnecessary duplication of senior management time;
- Culture Evidence Review - forensic analysis of the extent to which a firm's articulated culture is supported by demonstrable evidence;
- Senior Management Readiness and Assurance - training aimed at up-skilling and preparing those applying to the regulator; maximise the likelihood of obtaining regulatory approval and feel better prepared and supported in the role.
The expertise you need
Our approach is flexible and our services can be offered as a one off assessment or as part of a periodic review of governance arrangements:
- Assessment of how your firm's governance works in practice through attendance at board meetings, review of committee minutes and a representative sample of supporting documents, including any regulatory observations or challenges;
- Assessment of how governance is perceived to work in your organisation, this can include conducting interviews with individual board members, committee chairs and members as well as any other key decision makers;
- The identification of written documentation that supports your firm's cultural claims and which can be used in discussions with regulators;
- The identification of key hard metrics, which can be built into MI reporting and monitoring to ensure the cultural dial can be continuously monitored and measured;
- Training on personal obligations and duties imposed on Approved Persons and Senior Managers and managing relationships with regulators;
- Assessment of the needs of Senior Manager candidates, including a gap analysis of relevant skills, support with individual development plans and application documentation to support the regulatory application.
If you would like to know more or would like us to come and talk to you further about what we can offer, please contact us.