To remedy, we recommended a full assessment of the compliance function, highlighting any weaknesses or improvements to be made. A key aspect of this was to provide independent opinion on the adequacy of our client’s governance and oversight arrangements.
Initially, our consumer credit team spent time with the senior management team to gain a thorough understanding of the business model and to enable all regulatory requirements to be mapped to their activities.
We then reviewed the existing policies and procedures, highlighting gaps or weaknesses within the existing policy suite. Once new policies were drafted, or existing ones updated, any changes were consistently embedded and communicated, ensuring alignment with existing activity and training requirements.
We also reviewed the quality monitoring framework across the business. Our findings showed that the call monitoring process didn’t meet the lending and debt management requirements of CONC, so this was redesigned to incorporate the necessary standards.
As a result of the function assessment and redesign, the FCA was satisfied and the client was left with a compliance department that was more efficient and effective.