New Governance and Controls for New TOM
The Client’s Needs
The client, a UK broker with an overseas parent, was seeking to change its operating model to build a business which would be an incubator for new insurance industry intermediaries including MGAs and brokers with a heavy emphasis on technology. They were seeking to ensure speed to market and therefore were offering Appointed Representative status to the new firms they were incubating and/or investing in.
Lacking appropriate experierence, ICSR were asked to provide temporary resources to suport the business and undertake a review of the operating model and controls used by them for their broking and incubation business and to provide a report on meeting FCA expectations. ICSR were also asked to assist with recruitment of a full-time compliance officer.
ICSR provided a seasoned compliance resource from within the Talent Pool who provided the day to day resource leaving one of the ICSR Directors to undertake the review with insight from the resource. The report was completed identifying areas where work was required to improve the firm’s compliance with FCA requirements and risk management practice and ensure that the control environment matched the new operating model.
ICSR was then asked to implement the necessary remediation which it undertook in conjunction with the new full-time compliance officer ICSR had sourced for the firm to ensure that they understood the new operating model and would be able to operate it.
ICSR deployed a team of resources including experienced compliance and governance expertise to complete the work.
The client was able to carry through the development of its operating model while also ensuring that its business was fully supported with risk and compliance advice without disruption.