Case Study Drop Downs
The Brief – After an internal strategic review and external PRA examination, it became clear to our client that their operational risk management framework was flawed in a range of areas. With ambitious plans to re-engineer their whole framework and underlying system, our client counted on us to provide their far-reaching goals.
The Solution We were asked to undertake a number of key design and implementation roles within their transformation programme. As the driving force behind significant workstreams and projects, our team led the rollout of Three Lines of Defence model across the organisation which quickly came to be the catalyst and cornerstone for behavioural change.
Central in developing a number of components of the new framework, including creating the client’s first ever bank-wide control library and the team were also essential in leading the execution of a bank-wide risk assessment refresh, including taking responsibility for all follow-on training and education globally.
The Results – The client met every one of their regulatory commitments on schedule, including the release of their new framework, system and risk assessment recharge. The method which the team delivered this challenging programme has set a new bar for best practice within the bank and the client is delighted with the commitment, expertise and delivery skill the team has demonstrated.
We engaged our Pension Specialist who worked onsite and remotely, creating a report that was accepted by the senior management, including several recommendation (some of which they had implemented immediately) to provide a better and more compliant service.
Another tick in the box.
An insurance distributor had fallen behind with their Insurance Distribution Directive (IDD) project due to a rapid turnover of non-committed staff as well as numerous demands from their underwriters. Existing issues were complex due to multi-channel distribution through ARs and IARs. Customer journey’s were not identified and mapped, documentation was not prepared and there was minimal knowledge of the changes needed for the customer journey as a whole.
We set to identifying the entire distribution channel from brands through to individual products at this multi-million pound turnover business and identified numerous errors, inconsistencies and anomalies. A 6-week project turned out to be 8 weeks (mainly due to time taken in unearthing secrets) with some small areas remaining outstanding (but in hand) when we wrapped up the project.
Several projects were born off of the back of our work but the ultimate commitment to a risk framework was “to be managed internally” – this usually means that nothing will be done as the tone from the top was weak and incoherent. Strategically there were many issues that any risk-framework, would only have exacerbated at this time. We withdrew respectfully. You can’t win them all.
There was no budget for new software, so we updated the AML/CTF governance and created a KYC onboarding procedure that worked with existing systems. New controls were put in place and revised KYC assessment were implemented, fulfilling the client’s need and including all training and desktop process mapping to complete the governance suite.
Once the project plan was agreed the process would then take them through Option B to permissions being granted, then on to launch. There was an existing CCA function providing local business loans as well as mortgages through the Housing Act provisions for local authorities, and these were to migrate to the bank as and when the mobilisation phase was reached.
Specialist consultants were deployed to create the necessary areas for development of the business plan and co-ordinate the elements into a full application.
Compliance Consultant was asked to perform a gap analysis and project plan creation of a small financial operation including a bank.
The previous incumbent had left an array of notes but the dates and sequence were often missing. Our task was to collate, assess, analyse, apply to latest SMR requirements and identify the documents needed to be reviewed and updated. There were several external stakeholders including two sets of legal firms.
We created a workable and pragmatic action plan and identified the key steps, recording them on a project plan with milestones and phases differentiated for implementation. The project plan was created to include the whole implementation phase until March 2017.
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For ICAP plc (an Inter-Dealer Broker) Compliance Consultant (Formerly CEI Compliance) were tasked with reviewing and defining a new risk framework, loss reporting and streamlined, cohesive linked system to manage their risk exposure.
Here we identified misapplied rules and inaccurate ratings applied to the risk process. We identified time wasting elements and log-jams as well as disconnects and dead ends of the current system.
By re-engineering the process and creating a relevant and pertinent taxonomy, with risk identification along the lines of industry best-practice but specially formulated to identify the uniqueness of the client’s operations, we provided a range of solutions and options to assist in Risk Management and production of their annual ICAAP document, resulting in significant savings to their regulatory capital requirement.
It was soon evident that there was a need for an overall review of each and every sale as there was poor documentation and minimal suitability evidenced in any of the files. In a short time we assembled a group of specialist reviewers and completed the work within 3 weeks.
The final result was a fully compliant suitability appraisal of some very poor files and documented evidence that there was no duty of care demonstrated to even a “Treating Customers Fairly” standard.
The intention was to create as near as possible real time web based depositary from all the entities worldwide to provide the global position of all UK and dual listed securities.
Following on from this work the system was then expanded and we advised the inclusion of all global equities with the application of the data provided to the Research Department in Johannesburg to be able to have up-to-date positions so that they could declare any conflict of interest on any research material, a requirement by multiple jurisdictions around the world.
As part of the brief for the Zurich Banking Group, there was a need for an Operational Risk Framework to be rolled out worldwide. Originating from Switzerland this had been delayed for some time due to staff issues.
The banking group, unlike the global insurer, spanned four jurisdictions and each had separate processes that need to be identified, recorded (with primary and secondary controls identified throughout) and uploaded into the global main risk database in specific formats.
We coached and assisted the various process owners in the recording of the processes and facilitated further course design. Additionally, the reporting tool (SWORD) application needed implementation including training of all staff. Launch was co-ordinated to ensure required collation of all losses, near misses and breaches were fully registered, escalated and approved as appropriate.
These assessments were also checked against contemporary Treating Customers Fairly practice and the standards applied retrospectively, ensuring that the customers had a fair deal and that no one was given a bad customer experience.
And so much more ….