Skilled Person Reports
Ocreus is a Skilled Person panel firm for the following subject matter areas:
- Client Assets and Safeguarding (Lot A)
- Governance, Accountability, Strategy and Culture (Lot B)
- Conduct of Business (Lot D)
- Financial Crime (Lot E)
- Prudential – Adequate Financial Resources for FCA Solo Regulated Firms (Lot H)
We have extensive experience of providing Skilled Person reports, either under contract to the subject firm or the relevant regulator.
We approach Skilled Person reviews as an opportunity for the subject firm to rebuild or enhance its relationship with the regulator(s). We believe that the objectives of all parties – including the Skilled Person – should be aligned toward ensuring the subject firm achieves a sustainable, embedded level of regulatory compliance as soon, and as efficiently, as possible.
Any Skilled Person must ensure that they prepare a report addressing the required scope with independence, objectivity and technical competence. The regulator will rightly demand that the report provides:
- Clear evidence and conclusions to allow the regulator to manage the risk of non-compliance by the subject firm
- Information about the relevant areas of the subject firm’s activities that the regulator’s supervisory team needs
For the subject firm, it is essential that the Skilled Person brings forward pragmatic, appropriate suggestions based on an evidence-based approach. Many subject firms have an awareness of issues raised by Skilled Person reports; what they need from the Skilled Person is practical steps to assist the firm in addressing those issues efficiently.
Our experience of working on many Skilled Person reports over the years, and reflecting feedback from firms and regulators, leads us to go beyond the minimum necessary requirements above, and to focus on stakeholder management, clear and regular communication with all parties, a flexible approach to engagement challenges, and to developing innovative and pragmatic solutions.
For subject firms, the cost and stress of a Skilled Person review can be unwelcome. We firmly believe that as the firm is paying us to deliver a service, we need to work hard to ensure we deliver real added future value to the firm in return – not a bulky report simply reiterating the firm’s known challenges.
Consequently, our Skilled Person delivery teams are predominantly highly experienced practitioners and subject matter experts, not trainees following rigid checklists.
Skilled Person Preparation
Firms subject to a Skilled Person review will naturally want to ensure that they present the best view of their status and progress to the Skilled Person.
Often firm staff and management will have little or no experience of the Skilled Person process, and this may mean they will benefit from some preparation:
- Understanding the Skilled Person process
- Practice interviews
- Practice process walkthroughs
- Preparation for document requests and detailed testing
- Ensuring the Skilled Person process runs smoothly – managing the Skilled Person firm relationship
Skilled Person Related Remediation
Where Skilled Persons issue reports with recommendations, the regulator concerned will normally insist that all or most of the significant recommendations are implemented by the firm, and that the firm can demonstrate they are operating effectively and sustainably in BAU.
This requires a variety of activities to ensure the Skilled Person process can be closed off as soon as possible, by embedding the required changes. We often assist firms to accelerate these programs and built effective, sustainable BAU solutions. Our support can include:
- Remediation planning
- DD file remediation
- Transaction monitoring enhancement
- PEP and sanctions alert discounting enhancement
- Updating and enhancing policies and procedures, ensuring consistency and alignment
- Assisting with preparation of EWRA/BWRA and Risk Appetite Statements
- Assisting with preparation of Compliance Monitoring Plans
- Board Effectiveness Reviews and Board / C-Suite team coaching and development
- SM&CR / SIMR assessments including annual certification / fit & proper
- Assisting with Training Needs Analysis and training strategy
Please contact us here for Skilled Person services enquiries.