Review client’s governance, control and risk frameworks to ensure that the operating model remained fit for purpose
The Client’s Needs
The client, a medium sized broking group which had grown prudently organically and through acquisitions over a period of time, asked ICSR to review its governance, control and risk frameworks to ensure that the operating model remained fit for purpose and was meeting regulatory expectations given its growth and proposed future growth plans. ICSR were asked to “pretend they were the FCA paying a brief visit”.
Following standard FCA process pre-S.166 review, ICSR undertook a review of the operation of the firms governance structures through review of committee and board meeting papers and minutes as well as a review of the compliance and risk function documentation before undertaking a series of interviews. Thereafter a report was prepared and shared in draft before being finalised and presented by ICSR to the Board of Directors. The report contained a full schedule of areas where the firm’s practices required improvement and provided a pathway to achieve this.
ICSR deployed a team of resources including experienced risk, control and compliance professionals to help the insurer.
The client received a clear indication of whether it was meeting regulatory expectations and was able to plan for and implement remediation across its governance and control framework.