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Roll-Out of a Risk Framework Across a Banking Group

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A Swiss household name insurance group were

rolling out an Operational Risk Framework across

their global interests using defined methodology

coupled with a standardised and robust loss

reporting tool.

As a predominantly insurance based culture, the

banking group presented a slight challenge to

the architects insomuch as they appreciated

that the banks would have differing procedures

to the normal and they needed to be

accurately and practically interpretedfor the framework to be fit for

purpose.

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Whilst the financial reporting and general finance

function was straightforward and heavily

influenced by accounting practice, other areas

such as deposits, equity backed investments,

account handling and even compliance were

going to be markedly different.

Previous attempts at rolling out the system had

been flawed and ineffective due mainly to

the approach taken being too high level and

failure to engage the departments

at a meaningful level.

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The Framework fundamentals were sound and

universally acceptable but a solid understandingof the differences between the banking and the

insurance world was required and demanded an

open and honest dialogue with the various heads

of department.

A plan was formulated to deal with each part

of the framework and priorities were made

using customer importance as the main

criterion and ensuring that processes

were accurately recorded and thecontrols were adequately described

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As nobody was likely to understand the processesand controls like the process owners, they were

tasked with the mapping of the processes at ahigh level with all potential risk areas anappropriate controls at the required junctures.

A peer test would be conducted with the 2nd incommand and a quality assurance functionsupplied by us.

Fully documented details of the processesand a full evaluation of the controlsdesign and functionality with the

relevant COSO apportioned categorywas then uploaded to the centralrepository for reference.

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When all processes were identified with unique

references, a quarterly process owner sign-off

and 6 monthly full review was scheduled for each

department. Changes were coordinated and

phased to provide no loss of material

functionality to customers.

Senior management reviewed and approved

any changes recommended and reported

through the risk committee.

Global HQ were in overall command

of all data and version controlmanagement with trained local

support and liaison.

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The entire process then had to be interpreted andadapted to the European Head Office, the Isle of

Man International Operation and a final reviewand interpretation of the fiduciary function in theChannel Islands.

The commonality of the processes in the mainbanking arena had provided timesaving andcommonality that was applied across theother three areas.

The entire process was started at the beginningof September and scheduled for 6

months and the final documentedprocess was received before NewYears Evetwo months early!

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You are always dealing with the principalwhenyou are dealing with my firm. This means that I am the

relationship manager and there is no junior partner towhom responsibility will be transferred. There is nodecreased accountability, no "hand-off" to a less-informed colleague. If your interests are at stakecontinually, shouldnt you reasonably expect my

continual involvement? We can usually provide resources on a "just in

time" basis. That is, our projects do not have to coverexcessive overhead, such as multiple offices, largeadministrative backup, recruiting, partner perks, etc.

We are organized to efficiently provide everything thatyou, as the buyer needs, but nothing more than thatwhich means that you are paying for value and resultsand only minimum overhead.

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There is more likelihood ofyour privacy

and confidentiality being observed withfewer people working on the project. We(and/or the few people we might also involve)are constant which means that there isnt the

need to sift through dozens of differing

perceptions. Were faster. We can respond to requests

quickly, and return all calls within four hourswhich means to you that there is no need to

worry about a bureaucracy, delays andunknown people on the other end of thephone

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Since we handle fewer concurrent projects thanlarger firms, our attention is focused on the job at

hand. This means that you dont have to"compete" with another dozen or so of ourclients, which may be larger, paying more or aremore time-demanding. We structure our work sothatevery client receives maximum

attention. Your investment is controlled. There is no

"meter running". We work for a fixed, value-based, project fee. Large firms cant afford to dothat as readily because of all the people involved

and their own insistence on measuring theirsuccess by billable hours. We measure our successby client objectives reached, not in time units.

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The expertise that larger firms use is often white-labelling for them by a pool of consultants

available in the marketplace at any one time. Weselect our consultants frompractisingsubject matter experts which means thatyou obtain the same or better expertise for less

money, because;

Inevitably, we are less expensive. Thereare economies to using someone who can basetheir fees on each situation and not on a pre-

determined service scale or need for reaching apractice quota. This means quite simply bettervalue to you.

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We will conduct an initial appraisal at our cost only charging for expenses

We will make a proposal based on our

appraisal with your outcomes and needs

We will discuss the precise scope with you

and provide you with a project price

We will complete the work to your original

scope and satisfaction

Phase 1

Phase 2

Phase 3

Click Mouse Reveal Next Phase

Phase 4

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We have a wealth of Financial Services Experience, and due to

the remedial nature of our work forming over 60% of our

business and that is conducted under a Non Disclosure Regime,

we cannot demonstrate every client.

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We can provide all manner of assistance in

Initial risk assessment or audit an initial analysis toidentify higher risk areas of the business and weaknessesin procedures. We also do risk management design.

Business development business analysis advice oradvice on particular issues for example, how your firm isTreating Customers Fairly and an action plan for

implementing TCF across your business. Help with setting up procedures for example procedural

manuals for recruitment, training and competence,complaints handling and anti-money laundering. May alsoinclude templates for disclosure documents, fact-finds andregisters.

File audits checks to ensure that procedures are beingfollowed and identify good practices and weaknesses

Complaints Handling cost effective and project managedfrom start to finish making your response robust andconsistent

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We can provide all manner of assistance in;

Technical support may include advice on particularproducts or regulatory reporting. May be available invarious formats, including website, helpdesk and individualtechnical advice.

Training for example competency assessments, trainingopportunities or product risk guidance. May be online

support, regulatory updates or seminar based. Support on individual issues for example in dealing with

a complaint, a financial promotion or a particular suitabilityletter.

Financial promotions (all areas of advertisement) - fullsupport which would include websites, brochures, DVD's,

email templates, client mail shots, adverts, contactingexisting clients and so on.

Remedial work helping to action remedial workrequired by the FSA.

And much more just ask!

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CEI Compliance Limited

www.cei-compliance-limited.co.uk

Tel 0800 689 9 689 (UK)

Tel (+44) 7092 289901 (Int)

We operate across the UK, Europe

and the Middle East.

Currently exploring opportunities in

Latin America