“The action or manner of governing a state or organisation” (OED definition of governance)
In the regulated world, governance can take many forms and the regulators’ scrutiny of how firms organise themselves and organise their activities is becoming more intense.
A firm’s culture has been an ongoing theme for some time; personal responsibility and accountability will be brought into sharp focus by the Senior Managers and Certification Regime; and MiFID II will bring product governance firmly under the spotlight.
We can help you meet your organisational requirements – regardless of the sector you’re in or the scale of your activities. You’ll already have a Board or governing body of some description in place, but does it have the right composition; the right calibre of individual on it?
Whatever form it takes, the key question is whether the Board is effective or not:
- Does it provide the right level of challenge to the business?
- Is it receiving timely and accurate MI of the right kind?
- Do its delegated activities function appropriately?
- Is the committee structure right?
- With the right people in place?
- Do the committee terms of reference enable effective decision-making and escalation to take place?
- And how does risk management and compliance fit into the above?
We can help you answer these and other questions with a Board Effectiveness Review; benchmarking your firm with your peers and how you shape up to the regulators’ expectations.
Governance and Culture
Putting your customers first should be at the heart of what you do. Is this culture articulated clearly and is the tone set from the Board down? How do you describe your firm’s culture? And how do you demonstrate that you are putting customers first?
We’ve moved on from the early days of TCF, so the monitoring of your conduct activities and the outcomes you are achieving for your clients should give us a good indication. But have you identified all of your conduct risks? Do you have controls in place to mitigate or manage them? What MI do you generate to prove this to the Board?
If you’d like us to carry out a conduct risk assessment or sound out the culture in your organisation, give us a call.
The MiFID II product governance requirements now extend to services as well as products. So even if you are just a portfolio manager you’ll have to think about identifying your target market, working out who the service is not suitable for and monitoring that it’s actually being bought by the right people.
The new rules extend beyond these three points and are quite prescriptive for both manufacturers and distributors – building on, and fleshing out the RPPD, the FCA’s only guidance in this area for the last few years.
We can help you establish the right product governance framework or review and update the one you’ve already got. If you’ve got the right policies and procedures in place already, you might want us to give you an independent view of whether they are working and delivering the right outcomes.
There’s plenty more that might be troubling the Board; or there’s plenty more you think should be troubling the Board! Be it remuneration, conflicts, vulnerable customers, or outsourcing – we’ve got the experience to take a look.