Review of US owned firms UK Conduct Risk Framework
The Client’s Needs
The Compliance Officer for a large US owned insurance group required a review of the firms’ UK Conduct Risk Framework. The Framework has been in existence for several years and the firm wanted independent assurance that it was still fit for purpose or advice on possible enhancements.
- Undertook a full review of the Board approved compliance policies relevant to Conduct Risk and the Framework document itself reviewing design, operation, efficiency and effectiveness;
- Following the review key individuals’ within the firm were interviewed to assess their view of the effectiveness and efficiency of the framework and its’ output;
- Sample tests were undertaken of a series of binding authorities, products and complaints to determine the effectiveness of the framework on delegated underwriting arrangements and the oversight on outcomes for customers; and
- A report was prepared within the timeframe requested for upward reporting through the governance structure.
A member of the Talent Pool led the work with support from a Director of ICSR.
The Board of Directors was satisfied that the firm was meeting regulatory expectations for conduct risk and had oversight of recommended enhancements.