Case Study: Policy Review


The outcomes from a risk policy review

  • Material efficiencies where controls were simplified and responsibilities clarified

  • Reduced likelihood of regulatory intervention

More generally, if you are FinTech start-up or a Venture Capital owned businesses, enhancing your risk and control environment can also influence the terms of an exit.

Crescendo Advisors' Approach

Our approach includes a combination of the following:

  • Documenting a strategic approach to Board approved policies – including responsibilities for ownership, governance, implementation, attestation and review

  • Review of completeness of the policy suite, bearing in mind that there is usually more than one way of packaging requirements

  • Developing a standardised approach for policies that supports policy accountability within the business

  • Working with the business to ensure that policies reflect key regulatory expectations and business approaches

  • Designing a pragmatic approach for delivering policy updates and evidence of implementation, including executive and Board oversight

  • Support business review and policy implementation, engagement and training.

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The problem

Board-approved policies set out the high-level expectations for appropriate controls for risk-taking in the business. However, over time, insurers and brokers can accumulate several policies in different styles and formats, which may lack completeness and/or be misaligned with business and regulatory expectations.  There may be a lack of clarity over roles, responsibilities and timelines as well as business changes or grows.

It is also important to bear in mind that regulators will hold Boards and firms responsible for the commitments made in policies, even if these represent an over-implementation.  So over-promising and under-delivering can be a material regulatory risk.