A clear remediation plan is required when a regulatory gap or supervisory concern surfaces. Here is an overview of how consultants work through such a process.
Diagnosing the Root Cause
First of all, a good consultant doesn’t just fix a problem on the surface. He tries to get to the root cause of a problem. If there’s a problem with a regulatory gap or a supervisory concern, the consultant will trace the issue back to the root cause of the problem. That might be a policy issue, a training issue or a process that wasn’t fit for purpose in the first place.
Drafting a Structured Plan
A written remediation plan, containing specific actions with named owners and appropriate timescales for completion of each action, is required. The firm’s intentions for completion of each action must be measurable and the owner of each action held accountable for completion of each action.
Updating Policies and Procedures
Additionally, whilst a single document may be the subject of the concern, affected policies and related procedures will need to be reviewed and updated as necessary to address the root cause of the concern.
Communicating With the FCA
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Evidencing Completion
To consider the plan to be complete evidence needs to be gathered and organised in order to prove that all the tasks specified in the plan have been met.
A well executed Remediation Plan turns a problem into a solution.
