Robust advice governance led by senior managers and Approved Persons can ensure that changes to the advice frameworks and your services for customers are well managed and that important risks are surfaced early and dealt with. A simple structure of policy and proposition committees chaired by senior management and supported by strong risk, compliance and technical functions can act as a break on sometimes chaotic change and align your advice services with your business objectives and your customers’ needs as well as reducing unnecessary spend and distracting initiatives.
Enterprise Learning can independently assess your existing governance structures to validate them and advise on improvements, reviews which can be provided to regulators if required as proof of your commitment to strong governance. We can help you put in place a streamlined structure, developing Terms of Reference for your committees and Role Profiles for your senior managers. We can also help you ensure these groups and people receive the right management information as well as understand regulatory expectations and how competitor firms operate. We can also work with your Risk/Compliance functions to strengthen their approaches and help ensure their monitoring and policy approaches are effective as well as practical. If necessary we can carry out independent audits on behalf of senior managers or Risk/Compliance or provide specialist resource to help Risk/Compliance functions.
If necessary we can help you prepare for regulatory reviews and ARROW visits or manage your relationships with regulators after visits or when you are moving into new business areas.
- Appropriately skilled and senior people form an ‘Advice Standards Policy Group’ where the Firm’s Advice Policy is set agreed.
- Robust and effective Change Control procedures authorise any changes to Suitable Advice Standards, ensure they are appropriately updated, and a full archived record is maintained.
- Regular review of advice provision using appropriate MI allows senior management to identify and act on areas of concern.
- Major Advice Risks (including Conduct Risks) are identified and appropriate systems are in place to ensure these are monitored and managed.
- Decision makers appointed who do not have the required level of seniority/capability.
- Lack of change control procedures which allows haphazard changes or guidance without consideration and authorisation.
- MI is distributed but recipients do not use it or do not understand when they should take action/ what action to take.
- Risk Function assuming that because MI is available, the operational/sales side of the business is capable of using this data to identify risks and mitigate them successfully.