ADVANCED

Project Based Services

Cordium can undertake a variety of project based services, based on each individual firm’s specific requirements. Some examples of project work that we carry out on a regular basis, are as follows:

  • Regulatory Theme Assessments
    • The Financial Conduct Authority is continuing its predecessors emerging focus on thematic reviews and focused inspection visits. High level regulatory oversight based on governance and systems and controls has been found wanting, and whilst these remain important and central to relationship where the firm has a nominated supervisor, the majority of firms will be part of what FCA terms a “flexible portfolio” subject to event-driven and issue based review.The advantage for the regulator in this “pic ‘n’ mix” approach, is that regulators can become relatively specialised in their area of review, they import “best-practice” standards from the firms that form the initial sample of their review, issue a statement or consultation on their industry observations and apply those standards, identifying weaknesses or apparent shortcomings in a second wave of reviews. Where weaknesses are identified, the regulator will likely assume failures of systems and control and could seek remedial action or even commission a skilled person review.View more
  • Mock regulatory inspections and compliance assurance reviews
    • Cordium regularly undertakes mock regulatory inspections or compliance assurance reviews for clients. The driver for each review can be very different. Recent regulatory interaction in another jurisdiction, an absence for a significant period of any regulatory interaction, changes in senior management, a “near-miss” regulatory breach or failure in key control or simply time for an independent review and assessment.Cordium has completed regulatory assessments at all manner of firms, alternative managers, brokers, OPS managers, wealth managers, real estate investment managers, long-only managers, and we also deliver compliance monitoring programmes for large managers on a co-sourced basis.View more
  • New regulation analysis and implementation
    • The Alternative Investment Fund Managers Directive (“AIFMD”) is a significant regulatory change that Cordium has been tracking for many years and months. Cordium will conduct gap analyses for firms to help them understand the impact and implications of the new regulations. We track the new requirements as closely as possible, working with the regulator and HM Treasury in order that the necessary change can be implemented with as little fuss and fanfare as is possible, proportionate to the degree of impact and foundation in common sense the rules contain.View more
  • Operational risk infrastructure design and review
    • Operational risk has become increasingly important for investment management firms and will become more important with the implementation of AIFMD. The alternative asset management sector has not had to as much importance on the formal setting of risk appetite statements. Unlike the UCITS sector, exposures are passed to the funds through legal arrangements, something that appears to be gaining regulatory criticism from the FCA as it pursues its Wholesale Conduct agenda. Regulation will change the outlook for alternatives managers, but it is likely that these firms will still favour simpler definitions of risk appetite. Business models are not normally complex and managers looking to implement operational risk structures should look to exploit synergies with existing risk governance arrangements such as ICAAP.Cordium has experience of working with alternative investment managers implementing operational risk infrastructures.View more.
  • Post regulatory review remediation
    • Cordium has been approached by firms whose regulatory engagement has created new challenges for the Firm. We consider that our response to such situations is balanced and realistic, taking into account the seriousness of the situation and the need for careful management of resources and expenditure.We have collaborated with an Authorised Corporate Director to address serious FSA concerns regarding the quality of its risk management and outsourced supplier oversight. Our risk management and compliance capabilities provided a seamless solution to the ACD’s requirements.In another case we have been approached and provided consultative support to a wealth manager seeking to challenge the Financial Ombudsman’s assessment of discretionary management suitability. In both cases Cordium was able to draw on the extensive experience of our consultants to deliver solutions to the clients

Download our project based consulting brochure here.