Phase 2 Skilled Person report to assess front office control and governance remediation performed by a wholesale broker

The Firm had received a 2 phase Skilled Person Report to consider the robustness of front office controls and governance. Our work was to assess the adequacy and effectiveness of the Firm’s remediation following its Phase 1 report and determine the extent to which remediation was sustainable and embedded into operational practices.

We performed reviews of the Firm’s enhanced control environment, organisational governance and remuneration strategies to determine the extent to which the oversight of brokers was effectively discharged acoss the lines of defence and whether the Firm had aligned, culturally its reward structures in a manner that balanced performance, control and compliance.

We met with a series of key stakeholders including Senior Managers, HR staff members, Brokers and Desk Heads as well as second line of defence functions to consider how compliance and risk oversaw the processes and the broker controls within the first line. Our work considered whether Brokers are adequately supervised and whether the Firm’s requirements on front office staff engendered appropriate behaviours.

The Firm had made a number of enhancements and materially remediated its control environment. We advised the client on some additional areas for consideration, incuding the span of control for specific individuals, to improve the sustainability of oversight and mitigate future key person risk.