The four areas of work

1 Relationships with regulators go off track. It happens. The challenge is getting them back on track and I help firms do that.

There are times when every firm struggles to meet regulatory requirements, to work out what, exactly, regulators expect of them and how to comply whilst continuing to grow at scale. If a firm falls the wrong side of the regulatory line, the board and senior management are likely to find that regulators are on their case.

I work with banks and financial institutions – particularly, their boards and senior management – where the relationship with regulators goes awry. For instance, where:

  • The tone changes in letters from regulators;
  • Regulators say they’re “concerned” about aspects of the firm and its business;
  • Regulatory questions and information requests stray to other parts of the business; or
  • Regulators say they “just can’t quite get comfortable with” the firm and its activities.

I haven’t come across a problem that can’t be fixed and it’s perfectly possible to get the relationship with regulators back on track. I’ve been helping firms do that for many years.

2 – Governance: the topic that never goes away

One of the things regulators always look for is robust, effective governance and it’s a key reason they’re comfortable with current initiatives to reduce the regulatory burden: strong governance provides an overarching framework for regulatory compliance. And I’ve seen over the years that strong governance – governance that leads the field; a board that isn’t just effective but excels – is also the foundation of a thriving and resilient business. A business that’s able to grow, sustainably, over years and decades, not just over the next twelve months. One that’s attractive to investors and to funders and, where there’s an IPO on the horizon, strong governance can help that proceed more smoothly too.

I’ve prepared some notes looking at different aspects of governance and these are available at the Governance Reframed tab.

3 and 4 – The other work

I also advise on authorisation applications (including those for banks and e-money and payment institutions), using experience in addressing regulatory problems and governance work to support new businesses, explaining the areas regulators focus on and helping applicants establish good relationships with regulators from the outset.

As part of authorisation applications and as ongoing work, I:

  • Help candidates for senior management functions to prepare for SMF interviews with regulators and support firms in their preparation for regulatory visits; and
  • Work on controller (change in control) applications.

Doing the work

In each case, I draw on what I’ve seen in practice so I can identify what matters and why. There isn’t a single approach to work because every firm has different needs, objectives and circumstances and each regulatory incident is different. But when looking at governance, I use a set of criteria that I’ve developed.