Our client was a UK authorised bank that manages assets on a discretionary and advisory basis for clients, including individuals, families, trustees, pension funds and professional advisers. Cordium undertook a review of the status of the Retail Distribution Review (“RDR”) implementation with a view to providing confirmation that decision making is compliant with COBS, SYSC and TC requirements and confirmation that the project remained capable of being delivered to regulatory deadlines.
Our work sought to understand how the Firm has identified its regulatory requirements under the new rules and how the Firm has planned to implement the programme to meet these requirements. Cordium also assessed whether the client has identified the complete and correct retail COBS rules to comply with, whether the Firm has made a correct interpretation of the rule requirements, whether the proposed deliverables addressed the rule requirements and whether the project deliverables remained on track according to the planned delivery dates.
The review entailed knowledge of discretionary investment management services and packaged products used in the discretionary service, COBS and drew on knowledge from past business reviews
The Firm’s project governance was de-centralised which required independent review of each of the relevant workstreams. Certain decisions appeared to have been taken by a limited number of front-office facing workstreams that could have caused the Firm to receive regulatory challenge. Our work and the presentation of our recommendations on a draft basis facilitated the escalation of these concerns and their resolution by senior management.
Cordium regularly works with wealth management firms to assist them with compliance matters and in particular their Know Your Customer, suitability requirements and investment processes and client reporting requirements. We have experienced professionals that have worked in the retail sector and / or regulated retail investment firms.