OUR SERVICES

We don’t offer the pre-made but using our depth of experience we work within our clients business in order to ensure that what we design, build, implement or embed complements the rest of their existing governance, compliance, risk or control framework(s).

 

We offer three types of service:

  • An advisory service where we give advice on issues from the discrete to the more substantial impacting a larger element of your business model or governance and/ or control frameworks.
  • Complementary to the advisory work we can oversee and manage implementation of any changes required including embedding the changes utilising appropriate training methods to match the scale of your business
  • We also offer a resourcing option where clients have received advice internally or externally and only need additional resource to implement any changes.

The areas we cover and the services we can offer are detailed further below.

GOVERNANCE

We undertake corporate governance reviews and support annual Board effectiveness reviews as well as creating operating models and Policy Frameworks to compliment Risk and Control Frameworks. We can also assist with FCA/PRA Senior Managers Regime assessments and on-boarding for directors. Read more >

ICSR has considerable experience in dealing with corporate governance issues and can assist a business:

    • To design, implement and embed an appropriate approach to corporate governance
    • Supporting annual effectiveness reviews
    • Review and advise on arrangements including:
  • The effectiveness of the Board structure and use of Board Sub-Committees as well as non-Board Committees
  • Consider the appropriateness, completeness and sufficiency of MI used within the Governance structure
  • Consider the effectiveness of the Board and Board Committee preparation and administration
  • Review the use, independence and effectiveness of the Control Functions including Internal Audit, Risk, Actuarial and Compliance including considering their planning, reporting and oversight arrangements
  • Oversight of Conduct Risk and Product Development and distribution including Outsourcing arrangements
  • To ensure that good governance leads to the intended culture within the organisation
  • To consider and advise on compliance with FCA/PRA Senior Managers Regime requirements
  • To consider any impact of a corporate reorganisation and the need to ensure oversight and control of any transformational programme as well as ensuring that appropriate adjustments are made to the corporate governance arrangements arising from a change programme
  • Prepare for and respond to any external governance review by FCA, PRA or Lloyd’s
  • Support the remediation of any issues following an external governance review

START UPS

We are able to assist a new business with its’ application and implementation of all the necessary governance and risk, control and compliance frameworks and policies to ensure the business meets its anticipated legal and regulatory commitments. Read more >

ICSR has experience covering the areas which a new business needs to develop including:

    • Applications to regulators and supporting documentation including the regulatory business plan
    • Corporate governance requirements including FCA/PRA Senior Managers Regime and documentation evidencing segregation of responsibilities between individuals
    • Induction training for Directors, Senior Function Holders and staff
    • Proposed Board and Board Committee structures and membership
    • Corporate governance documentation including terms of references for Boards and Board sub-Committees such as Risk, Audit, Compliance, Remuneration and/or Nominations
    • Advise on Compliance resourcing requirements
    • Develop a Compliance Plan including Monitoring Plan
    • Prepare Compliance Framework which will match the business and operations and be drafted to match FCA/PRA Senior Managers Regime and other corporate governance requirements as well as Compliance and Conduct Risk requirements and structures including as appropriate:
  • Compliance
  • Risk
  • Conduct Risk
  • Financial Crime (AML, Fraud, Sanctions)
  • Underwriting
  • Product Governance
  • Fit and Proper including Training and Competence
  • Conflicts of Interest
  • Data Protection and Privacy
  • Whistleblowing
  • Outsourcing
  • Complaints
  • Develop with the customer appropriate systems and controls creating processes and procedures to ensure compliance with the corporate governance requirements and internal policies supported by appropriate monitoring and reporting
  • Prepare manuals outlining the developed processes and procedures for all aspects of the business including underwriting, sales, servicing, claims and complaints
  • Development of telemarketing and teleservicing scripts
  • Develop Compliance Risk indicators and reporting procedures including governance MI for Conduct Risk
  • Develop training for employees (either in whole or on a “train the trainer” basis) including induction programs for new employees and Non-Executive Directors
  • Develop product governance and lifecycle processes
  • Develop sales documentation such as policy summaries

ADVISORY

We have the capability to help businesses ensure they are operating good practice in areas as diverse as Financial Crime, Conduct Risk, Data Protection and Privacy and Product Governance and can undertake Compliance Department effectiveness and resourcing reviews to ensure that the controls are in place and operating effectively with appropriate MI getting to the right place. Read more >

ICSR is well versed in helping businesses with the following:

  • Operational corporate governance, systems and controls and processes and procedures
  • Annual compliance Plan development including Monitoring Plan
  • Senior Managers Regime controls and effectiveness
  • Conduct Risk issues relating to:
  • Products and product governance
  • Distribution and third party arrangements
  • Management Information and reporting
  • Servicing and third party arrangements
  • Training and competence
  • Complaints handing
  • Claims handling
  • Development and implementation of change resulting from regulatory change or operational change such as the implementation of new technology
  • Development of risk and control frameworks including compliance
  • Compliance department effectiveness and strategy
  • New product Development including:
  • Conduct Risk Issues
  • Value proposition
  • MI thresholds and reporting
  • Impact of proposed distribution models
  • Product Governance issues
  • Review of:
  • servicing, complaints and claims policies and procedures including telemarketing and teleservicing scripts
  • status and product disclosure
  • DMD requirements for websites and marketing materials used internally and by third parties
  • Training for sales, servicing, claims and complaints staff
  • Product cessation and run-off of books of business
  • Legacy book reviews for compliance and remediation requirements
  • Whistleblowing:
  • Development of policies and procedures
  • Training
  • Development or review of early warning systems and culture
  • Role of the Whistleblower’s Champion and governance

RESTRUCTURING

With the need to remain competitive and the legal and regulatory landscape changing we are well placed to support transformation projects required by a business in response to Brexit or post-acquisition. Read more >

ICSR has considerable experience of overseeing and managing reorganisations and restructures within financial services firms and are able to provide:

  • Advise on and manage:
    • Corporate governance and project governance requirements for the transformation project
    • Risk and control framework implications
    • Coordinate between the various business units and risk, compliance, legal, finance, tax, Ops, IT, HR and communications
    • Review licensing issues
    • Reviewing Data Protection issues
    • Corporate insurance and reinsurance implications
    • Third party contractual arrangements
    • Customer communications
  • Support on realignment of:
    • Compliance Department resources
    • Annual Compliance Plan
    • Compliance and Corporate Governance Policies
    • Realignment of procedures for compliance including review of procedures in underwriting, sales, servicing, claims and complaints
    • Revising procedures manuals
    • Realignment of Conduct Risk implications
    • Realignment of SIMR requirements
    • Realignment of Governance and Compliance MI
  • Support preparing reports for Executive Committee/Board
  • Project Management resource support for Part VII process
  • Support and resources for Part VII arrangements including:
    • Preparation of applications to and liaising with regulators
    • Support for collation of evidence or fact for preparation of Court Application and supporting documentation
    • Assisting in the preparation of any actuarial report required to be completed
    • Preparation of customer communications strategy and documentation

REGULATORY ENGAGEMENTS & INTERVENTION

It is now commonplace to have the regulator reviewing the practices adopted by the industry, a segment or a particular business. We can assist where help is needed to prepare for or respond to a business’s need to change following a new consultation paper, a thematic review or the appointment of a skilled person. Our role can be as diverse as supporting the review or assisting in the implementation and embedding of any recommendations following such review. Read more >
  • Support in considering and responding to consultation papers and other regulatory changes
  • Assisting with preparation for and response to ongoing regulatory oversight
  • Corporate governance effectiveness reviews
  • Review nature and effectiveness of compliance and control frameworks including internal policies and underlying procedures
  • Review effectiveness of monitoring and reporting
  • Product governance and lifecycle
  • Thematic reviews:
  • Advise on regulatory intent and background
  • Review scope of review
  • Advise business on response
  • If required prepare individuals for interviews and support documentation collation
  • Advise business and management on impact of outcome if required
  • Internal investigations
  • Regulatory investigations
  • Whistleblowing investigations
  • Preparing for, advice on and developing response to Section 166 appointments
  • Advising on appropriateness of scope
  • Managing process including preparing individuals for interview
  • Reviewing draft report and advising on appropriate response
  • Reporting to management on outcome
  • Support for any past business review
  • Product remediation following S.166, Thematic review or other regulatory oversight
  • Third Party distributor reviews – IARS, ARs, and DUAs

TRAINING

A key element to effective risk, control and compliance frameworks is the embedding of the Board Policies and underlying Processes after delivery or transformation. We can support the embedding process with training from experts with years of experience. Read more >
  • Training and competence regimes for:
  • Senior Managers and Senior Function Holders
  • Induction programs for NEDs and Executives
  • Sales, servicing, complaints and claims staff
  • Training for sales, servicing and claims staff following the development of a new product
  • Training for staff following regulatory transformation programs in order to embed the changes
  • Introduction to insurance training for recruits
  • Introduction to regulation training for recruits

CO-SOURCING

Where you are early in your business’s life and/or have limited resources and budgetary constraint, growth or peak activity periods means you require additional assistance. We offer the ability to co-source certain activities relating to Company Secretarial services, Compliance, Risk or Internal Audit for limited or extended periods. Read more >

Company Secretarial

We have considerable company secretarial experience and offer a full panoply of company secretarial assistance. including:

  • Corporate Calendar Management including:
    • Year end and accounts filings
    • Lloyd’s deadlines/regulatory filings
    • Internal Model requirements for capital approval and model approval dates
  • Preparation of Board and Committee packs
  • Meeting minute taking and preparation
  • Routine minutes such as banking mandates
  • Recording and follow up of action items
  • Companies House filings
  • Annual reviews of Articles of Association or Conflict Management requirements

 

Compliance

Our combined experience can cover the full any of the following:

  • Licensing queries
  • Perimeter guidance on products or business models
  • Product development and lifecycle
  • Product and customer documentation
  • Financial crime queries including sanctions, AML, gifts and entertainment
  • Annual policy and manual reviews
  • Data Protection/GDPR queries
  • Monitoring
  • Development of Annual Plan
  • Regulatory reporting calendars
  • Complaints advisory or review
  • Training development and delivery
  • Appointed Representative Oversight

 

Risk Management

  • Development of the Annual Plan
  • Maintenance and update of risk and control register
  • Review of risk appetites and tolerances
  • Preparation of risk dashboards
  • Performance of deep dives into specific risks
  • Project risk reviews
  • Preparation and execution of risk surveys/questionnaires

 

Internal Audit

  • Development of the Annual Plan
  • Subject matter, business line, function or other specific audits
  • Project audits
  • Culture audits/questionnaires
  • Thematic audits
  • Audit quality reviews and coaching
  • Design of Audit Committee reporting

 

REGULATORY APPLICATIONS

There are many times when applications need to be made to regulators. We assist clients with applications to regulators whether at the start of the business’s life or during operations. Read more >
  • FCA/PRA licences for regulated activities and products
  • Voluntary variations of permission
  • Senior Manager approvals including interview preparation
  • Appointed Representative Notifications
  • Waivers and consents
  • Support for international licenses

 

REVIEWS

Good practice, stakeholder needs and regulatory expectations require reviews on various cycles. We support firms with internally-led reviews and those where there is an obligation for an external independent assessment. Read more >

Annual Board Effectiveness Review

The UK Corporate Governance Code and regulatory expectations require an annual board effectiveness review, which should be conducted by an external reviewer at least once every three years. The quality of the review undertaken will itself reflect on the quality and approach of a board to governance as a whole. More often than not, the approach taken should include a review of the culture of the firm as well.

We can assist with the design and planning of the annual review, help with the delivery and reporting, or perform an entire independent external assessment.

We always tailor our approach to the needs of the company and work with the Chairman to agree the specific activities.

Annual System of Governance/Control Review

Solvency II firms are required to undertake an annual review of the system of governance. These reviews can be time consuming and an inefficient use of internal resources during peak periods. In addition, it is good practice to have a review undertaken by an independent third party from time to time, not unlike the annual board effectiveness review.

We have experience at these reviews and have developed a methodology and approach. Like our other services we aim to bespoke our approach to the requirements and culture of our clients.

Control Function Reviews

From time to time changes in a business, function or the environment may drive the need to review the resources and/or effectiveness of one or more of the control functions: Compliance, Risk and Internal Audit. In the case of Internal Audit, the global professional standard requires an independent external effectiveness review be undertaken every 5 years. Our experience allows us to undertake reviews of all these functions impartially, benchmarking against regulatory expectations and market best practice. We have developed a methodology and approach to ensure that the review takes account of the business, its nature and size. We also conduct reviews of the three lines of defence arrangement in totality, looking at the effective functioning, interaction and reporting of the control and assurance functions.

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