Advising International Firm On Options For UK Structure Post-Temporary Permissions Regime
The Client’s Needs
The client was a multinational insurance group which specialised in run-off business with entities in the EEA and the UK as well as UK branches. The firms had been admitted to the Temporary Permissions Regime by the FCA and PRA.
ICSR were engaged to:
- Review the firms’ position and advise the group on the regulatory position under the TPR
- Advise on Governance and Compliance issues related to the TPR,
- Assist the client to make its decision about the appropriate structure post-TPR (branch or subsidiary),
- Assist the client to prepare its Authorisation Applications, which are ongoing including:
- Assist the firm to identify and employ suitable candidates for roles of Heads of Compliance, Risk and Actuarial, and
- Provide a project manager to support the work required to complete the authorisation applications and build a PRA and FCA compliance governance and control framework.
ICSR continues to provide the advice and support required for the applications including:
- Reviewing and advising on the contents of the Regulatory Business Plan,
- Assisting and advising on the appropriate governance structure,
- Helping with assessment of the approach to take to regulatory capital
- Advising on and drafting documentation for the development of 3 Lines of Defence including Risk and Compliance Frameworks which included ORSA processes, risk and compliance Policies, tolerances and assessment processes,
- Advising on and assisting with other aspects of the Scheme of Operations,
- Completing the formal application documentation, and
- Training the Senior Management Function holders on their duties and responsibilities and prepare them for interviews with the PRA and/or FCA.
ICSR also continues to assist with the process of creating a new governance and control environment using its resources while also assisting the firms to identify the individuals to be hired by the firm to take on the appropriate roles with the necessary skills and experience in the London Market.
ICSR deployed a Director to provide the advice, a senior compliance consultant to provide the compliance support and a programme manager from the Talent Pool to help build the new control environment.
The client is on track to complete the applications and progress their proposed applications.