Robust and effective governance in a regulated firm is a business imperative. A structured, flexible and tailored control framework is an essential business tool to achieve this and provides competitive advantage.

Bespoke Governance & Regulatory

Control Frameworks for Regulated Firms.

Achieving high regulatory standards is a critical requirement for all regulated businesses. The impact of the Senior Managers and Certification Regime and the ever-increasing responsibility and accountability for Senior Managers to achieve high cultural and regulatory compliance standards should not be underestimated. Ensuring clearly defined arrangements to facilitate the achievement of good governance supported by robust records is essential to deliver and demonstrate how high standards have been maintained.

Regulatory

Control Environment

Ethical and cultural tone set from the top and effective governance oversight.

Risk Assessment

Identification, impact assessment and allocation of ownership of key regulatory risks.

Control Activities

Policies, procedures and processes identified as key controls, linked to key risks and key regulations.

Monitoring Activities

Ongoing monitoring, thematic reviews and audits to assess effectiveness of Control Framework.

Information and Communication

Acquisition and generation of information from internal and external sources to support senior manager regulatory responsibilities.

Regulatory Control Framework

What we do

Bespoke GRC offer a range of services to assist firms tailor and optimise their regulatory control frameworks. Services provided to firms will differ depending on the needs of the client reflecting the delta between their “as is” state and their optimum state.

• For new firms this could include a design, implementation and embedding service. For other firms this may be assessment, refinement and roll-out services.

• Our highly-experienced Governance, Regulatory, and Compliance practitioners, will review your governance and regulatory control environment helping you ensure you have a sound governance framework around your business strategy and operational needs.

• We deliver solutions that integrate seamlessly within your operational and control requirements to ensure that the right resources are in place to maintain your Regulatory Control Framework post- implementation.

• We can also provide support to individual Senior Managers with new roles or responsibilities through our innovative “in-

placement” service, Bespoke GRC 100.

Our Expertise

With a combined experience of over 75 years in financial services, we are a team of experienced professionals with a proven record of building and operating governance, compliance, assurance and regulatory functions from within a broad range of regulated businesses.

• We have lived many of the challenges our clients face and we have built governance, regulatory and compliance functions and frameworks from inside regulated firms.

• We have senior management experience across regulated firms including retail banking, mortgages and insurance.

• We have worked in start-ups, turnarounds, right-sizing and established firms and understand the different challenges each change process brings.

Our team credentials and areas of specialism

Our teams’ credentials and areas of specialism

Legal and Governance – Zoe Bucknell

As an experienced General Counsel and Company Secretary, Zoe has extensive experience in building and developing teams across Legal, Company Secretarial, Compliance and Regulatory Affairs functions. As such, she brings a practitioner led approach to working with executives to design and deliver organisational change to better align compliance, governance and regulatory functions to strategic goals, operating models and regulatory change management.

Zoe has significant financial services experience spanning two decades and has a proven track record of being a trusted adviser to Boards in delivering strategic and governance guidance in rapid change environments, with an ability to quickly build relationships through a deep understanding of financial services businesses and effective communication at all levels.

Zoe has built governance frameworks for firms listing on both AIM and Main Market, compliance and regulatory frameworks in the retail insurance and retail bank sector, and most recently managed the implementation of the Senior Managers and Certification Regime (SM&CR) at a Challenger Bank.

Compliance and Assurance – Stephen Whittingham

With over 15 years’ experience in senior compliance and financial crime roles across a range of small and large regulated firms with multiple product offerings, Stephen brings a wealth of experience and knowledge to BGRC.

In particular, his expertise in the effective operation of Compliance and Financial Crime functions including assurance, policy and business support disciplines is considerable.

With a proven track-record in aligning Conduct of Business rules to regulatory requirements, he is a trusted adviser to senior management helping firms in achieving high compliance standards through commercially sensitive and pragmatic solutions.

Regulatory Affairs – Donald Davies

As a Regulation Interpretation specialist and Regulatory Change Management practitioner, Donald has extensive experience in helping regulated firms identify, navigate and manage the ever- changing regulatory landscape. This is achieved by implementing a regulatory change management framework that is proportionate to the firm’s size and complexity.

Recent work has included oversight of the interpretation and implementation of the European Mortgage Credit Directive (EMCD), as well as the Senior Managers and Certification Regime (SM&CR), whilst building, developing & mentoring a dedicated Regulatory Affairs teams. Working across the regulatory life cycle of products, processes, policies and procedures, Donald helps firms make Regulation-led change assessment along with a review of existing and future strategy, to:

best meet and exceed regulator-driven requirements, meet their responsibility to comply with requirements and standards of the regulatory system, remain within accepted Regulatory Risk appetite.

Recent work by our Directors for regulated firms

Senior Managers and Certification Regime implementation

Assessment, interpretation and adoption of Regime requirements.

Challenger Bank - England

European Mortgage Credit Directive implementation

Assessment, interpretation and adoption of regulation

Challenger Bank - England

Group Governance Framework

Mapping of Governance, Policy and Procedures

Challenger Bank - England

Compliance Risk Framework

Assessment, interpretation and adoption of requirements into new operating model

Challenger Bank - England

Our Approach

We can, if required, provide an end to end solution consisting of discrete stages including initial analysis (and assessment of your current environment), designing, testing, implementing and embedding.

• Our flexible approach and pricing structure

enables our clients to choose all or some of the stages tailored to suit their individual needs and preferences.

• We offer an expert practitioner-led approach that

draws on in-depth knowledge of working within a broad spectrum of financial services businesses.

• Our mission is to increase the efficiency and value

of outputs from your Regulatory Control

Framework, whilst delivering enhanced control.

Our Philosophy

Our ethos is that a thoughtfully designed, sensitively implemented and robustly embedded Regulatory Control Framework will bring benefits beyond just best practice regulatory compliance, including:

• Providing Senior Managers with effective oversight

and regulatory knowledge in respect of their areas of responsibility, enabling them to better meet their regulatory responsibilities to take reasonable steps to fulfil their Statutory Duty of Responsibility and the Conduct Rules, AND in turn, spend more time fulfilling the firm’s strategic objectives.

• Delivering efficient and timely regulatory change

management procedures which can reduce the impact on resource requirements in both assurance and business departments for managing regulatory change, allowing BAU resource to remain focused on existing business priorities, whilst aligning to future operating requirements.

• Augmenting well-designed compliance assurance procedures which will help you to deliver enhanced consumer outcomes.

Helping you in building your enhanced regulatory control framework

Regulatory Control Framework elements

Analysis and Assessment of your current requirements

Design & Test Implement & Embed

Regulatory Control Environment

Clearly documented and communicated Governance Framework and articulated Ethics and Culture policy.

Risk Assessment

Forward and backward looking regulatory risk identification and impact assessment.

Allocation of key regulatory risks to accountable individuals and creation of a Regulatory Dashboard

Control Activities

Clearly documented, communicated and effective policies and procedures linking key regulatory risks / rules to related process and controls. Defined and implemented compliance function strategy, scope, structure, objectives and

responsibilities.

Monitoring Activities

A bespoke, risk based assurance model and framework.

Information and Communication

Effective attestation process giving Senior Managers assurance around their delegated responsibilities and areas of control. Defined and created, bespoke reports integrated with governance framework.

Key contacts:

Zoe Bucknell Managing Director – Legal and Governance

+44 (0) 7718 951 550 zoe.bucknell@bespokegrc.com

Donald Davies Managing Director – Regulatory Affairs

+44 (0) 7557 906 450 donald.davies@bespokegrc.com

bespokegrc.com

This publication has been produced only as a guide. No responsibility can be accepted by us for loss occasioned to any person acting or refraining from acting as a result of any material in this publication.

© 2016 Bespoke GRC Ltd. All rights reserved.