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Insights

SM&CR Series Insight 3: Employee SM&CR Compliance

The aim of this post is help you, an employee of an insurer, to be aware of the Conduct Rules and provide some practical guidance on complying with them. Your employer is responsible for providing you with training and making you aware of the Conduct Rules. Your employer is also responsible for ensuring that the process of complying with the Conduct Rules is properly documented. Now that we’ve covered your employer’s responsibilities, let’s look at […]

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SM&CR Series Insight 2: Senior Manager SM&CR Compliance

The aim of this Insight is to breakdown the Conduct Rules for Senior Managers, who are the most senior people in your company and have the greatest potential to harm market integrity. Rule 1: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively. This means that you need to establish effective processes to ensure that you are aware of what you’re responsible for […]

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SM&CR Series Insight 1: Employee Oversight

Insurers, get ready to put your governance under the microscope. The Financial Conduct Authority (FCA) will be extending its Senior Managers and Certification Regime (SM&CR) to the insurance industry by the end of 2018. It will replace the Senior Insurance Managers Regime (SIMR). Compared with SIMR, SM&CR will challenge insurers to think more critically about their governance arrangements. But don’t worry, time is on your side for now. During this critical thinking process, we recommend […]

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Operational Resilience – SKT Consulting in CityAM

It was great to see that an opinion letter submitted to CityAM by one of our Directors, Mark Rees, was published in the paper on Friday 10th August 2018. It covered operational resilience, and we hope it encouraged debate and moves resiliency up the agenda. You can find Mark’s letter on page 12 of the paper here: http://www.cityam.com/assets/uploads/content/2018/08/cityam-2018-08-10-5b6cc86dabdda.pdf You can find the full article here: http://www.sktconsulting.com/insights/moving-operational-resilience-up-the-agenda/

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Moving operational resilience up the agenda

I have witnessed an operational resilience team convene without its chairman, a divisional head shouting for a service to be recovered immediately and a COO stamp their feet. Consequently, I read with keen interest the discussion paper published by the FCA, BoE and PRA on operational resilience. The approaches I’ve seen to operational resilience range from the full ‘belts and braces’ to the minimum effort, and everything in-between. Those who do the minimum do so […]

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The inside track on a client engagement…

The Insight Interview featured below was conducted by Peter Foster, a Director at SKT Consulting featuring Edward Bragg, an Associate Manager following a successful two-year project at a Tier 1 Investment Bank.  Peter Foster (PF): Tell me a little about yourself? Edward Bragg (EB): My name is Edward Bragg, I have been at SKT Consulting for just over two and a half years. I have been fortunate to work on a variety of interesting and […]

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Book Review: Damaged Goods…

Damaged Goods –The Inside Story of Sir Philip Green. the Collapse of BHS and the Death of the High Street. Wow, what a read! Over the years, Philip Green has rarely been out of the news, but how much did I really know about the man behind the headlines? Truthfully, not a lot. True, I have seen him on the cover of magazines, watched him pose with model Kate Moss at fashion shows and envied him sunbathing on […]

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Book review: The City…

The City: London and the Global Power of Finance London has utilised its strengths to become the centre for international finance, but that is now in question. This is evident in London having the largest share of the global FX market ($5 trillion/day traded) and the financial derivatives market, and hosting a leading amount of international companies on the London Stock Exchange. In The City, author Tony Norfield uses his twenty years’ experience to explain how […]

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Learning from the past to implement IFRS 17…

I recently attended the IFRS 17 Forum put on by the Center for Financial Professionals. It was a great opportunity to network with colleagues in the insurance industry. Additionally, it provided me with a chance to reflect on some of the key themes surrounding this new regulation, which, once implemented, should improve financial reporting by providing more consistent, uniform, and transparent information to investors and policyholders. Commonly occurring discussion points included: the lack of IFRS […]

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Embracing RegTech – how financial institutions can and should embrace RegTech

With more regulation and limited resources comes the requirement for faster and easier ways to comply with regulations. This requirement has been filled by the proliferation of RegTech companies, who offer services as varied as interpreting new regulations, fraud prevention, and risk management, to name a few. But why should financial institutions use RegTech? According to some estimates, compliance costs firms roughly $1 billion per year, on average. This number is unlikely to decline anytime […]

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How can regulators facilitate RegTech adoption?

We are beginning to see regulators around the world facilitating the adoption of RegTech. In Asia, electronic-Know Your Customer (e-KYC) products have been rolled out by two regulators, the Monetary Authority of Singapore (MAS) and the Financial Services Regulatory Authority (FSRA) of Abu Dhabi. MAS began with a pilot programme collaborating with two Singaporean banks that linked to trusted, government-collected personal data sources to be used for KYC purposes. If MAS finds the pilot successful, […]

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Data Series Insight 4: Managing the Change

Data Series Insight 4: Managing the Change In the previous Data Series Insight, I laid out an approach to creating an enterprise-wide solution for data. Whilst this is a much needed and necessary task, I made it clear that it is both a resource and time heavy commitment. Nonetheless, by taking incremental steps financial institutions can begin this process. Firstly, they need to agree on their strategic objectives for their own data – what is the end goal? Secondly, a technology solution […]

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Data Series Insight 3: Enterprise Change

Data Series Insight 3: Enterprise Change The third instalment in our Data Series Insight focuses on the numerous benefits that can accrue for financial institutions that undertake enterprise-wide changes to better understand and handle their data. We have noticed a pattern of problems that afflict data at financial institutions, such as duplication of data; processes that are repeated and/or not streamlined; and processes that require specific applications to run and analyse their data. As a […]

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Data Series Insight 2: Changing the Culture

Data Series Insight 2: Changing the Culture Following the financial crisis, the introduction of BCBS 239 (Basel Committee on Banking Supervision: Principles for effective risk data aggregation & risk reporting) started the ball rolling for improved data governance across financial services. Since then, MiFID II, Dodd Frank, FRTB and GDPR have all added to this data burden. Consequently, financial institutions have invested heavily in enhancements to their technology. Now, data, combined with technology, is considered […]

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Data Series Insight 1: Setting the Scene

Data Series Insight 1: Setting the Scene Tired of not being able to get hold of the correct data? And when you do get it to review for that all important meeting, it is from multiple sources, in different formats, and is incomplete. Sounds familiar? Financial services have focused on streamlining processes and gaining a competitive advantage through ever more advanced technology, yet data remains the poor cousin which is resulting in inefficiencies and barriers […]

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FRTB concerns send blood pressures soaring

How’s your blood pressure? Another upcoming regulation is the Fundamental Review of the Trading Book (FRTB), which comes out of the Basel Committee’s overhaul to market risk capital requirements. As with most regulations originating from Basel, it’s subject to continuous updates but this makes it difficult to etch in stone certain implementation dates. That’s just one reason why this regulation may raise some people’s blood pressure. For more, read on. Updates are perhaps more likely […]

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GDPR: Are you ready for the four little letters that mean so much?

With the implementation of the General Data Protection Regulation (GDPR) just around the corner on 25 May – you know: those four little letters you keep hearing about – it’s important to ask yourself if your company is actually ready for it. What I mean by this is: has your company implemented a tactical band-aid solution to simply ensure compliance come 25 May – or do you have a strategic long-term solution? If it’s the […]

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Brexit represents the ultimate moving target

The uncertainty that Brexit has created is unprecedented and potentially requires significant planning on the part of financial service firms. The political agreement at the end of March on a transition period, set to last until 31 December 2020, is currently only a political agreement, which means that it is not codified law and therefore open to further changes. The transition agreement has still not resolved some of the original sticking points, namely the issue […]

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IFRS 17 demands more granular reporting for insurers but help is at hand

They say a change is as good as a rest, though it may not apply in this case. Large-scale change is coming to the insurance industry (again!) with the introduction of the International Financial Reporting Standards 17 Insurance Contracts (IFRS 17) by 1 January 2021. The regulation will involve more granular requirements, so I’m afraid rest is definitely not on the cards for insurers. Broadly, the aim of IFRS 17 is to set out the […]

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Basel III puts financial industry on a steady course

Keeping a ship on track is a complex affair. A skilled helmsman maintains a steady course, correctly executing each rudder order and using visual references, a magnetic and gyrocompass, and a rudder angle indicator. Just as the helmsman keeps a ship on track, so it is with Basel III and the banking sector. Basel III is the third accord from the continuously-updated Basel Committee. This comprehensive set of reform measures was developed to strengthen regulation, […]

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Whistleblowers, opportunists and disgruntled workers – the reality of the Insider Threat

This is a true story. A disgruntled employee who was angry about being passed over for a promotion, frustrated with his workload, in debt, and going through a marriage breakdown, snapped and decided to ‘take it out’ on the bank where he worked. Out of revenge, he stole client information from a customer database. He intended to use it at a new employer. Thankfully, his crime was detected. But the bank learned the lesson, and […]

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Company Culture: moving it up the business agenda

Culture is all around us. It is like oxygen, ever present. However, it’s often taken for granted and, in my experience, we only truly consider it when it’s under threat and at risk. So, having read the Financial Conduct Authority view on reforming culture, I welcome their call to put changes in culture ‘front and centre’. During the 2008 financial crisis, Barack Obama’s chief of staff, Rahm Emanuel, was fond of saying, “you never want […]

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The Day of the MiFID continues to impact financial services

It took effect in January 2018 but will impact businesses for the foreseeable future. I’m naturally talking about the Markets in Financial Instruments Directive II (MiFID II). This major EU rule update affects nearly every aspect of the financial services industry. If you’re finding it onerous and complex, you’re not alone. After all, MiFID II has over 1.7 million paragraphs of provisions. MiFID II builds on its 2007 predecessor to bring greater transparency and harmonisation […]

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