Skilled Person Report to assess governance arrangements and the firm’s oversight of its brokers’ conduct

Our client was required to commission a report into the adequacy and effectiveness of its organisational governance and the adequacy and effectiveness of the systems and controls in place to ensure that its brokers acted in accordance with regulatory requirements

We performed a detailed analysis of the firm’s governance structures and the adequacy and effectiveness of the reporting provided to each forum, including coverage and data quality. We considered data arising from the first line of defence controls, issue escalation arrangements and the data provided by the firm’s risk and compliance communities.

When considering controls at desk level, we evaluated the controls applied by desk heads and supervisors and how these were implemented across a range of different teams and brokers, including some higher performing individuals. We assessed these controls against the work being performed by the second and third lines of defence and overlaid other conduct related infrastructures including issue escalation arrangements, broker and supervisor remuneration and SM&CR.

The outputs of each of these elements were aligned to provide an overall assessment of organisational governance and control across each line of defence.

Whilst there were no indications of any conduct issues, we identified opportunities for the firm to enhance its internal reporting and governance structures. These provided management with a clearer and more robust line of sight of any issues and emerging risks. This will help the firm address the regulator’s immediate concerns as well as develop arrangements that will meet its Consumer Duty expectations.