Whether you need help in interpreting and implementing a new regulatory change or you simply want to “sense check” conflicting views…
At Themis Consultancy we offer sound commercial experience and a wealth of compliance knowledge and expertise to assist firms, whether it be navigating through the regulatory landscape, liaising with the regulator or identifying and mitigating risk. This means we are able to help firms to balance compliance, customer and commercial needs, whilst delivering the outcomes the regulator will expect.
Above all, the FCA expects authorised firms to ensure they are treating customers fairly and this means all firms must be able to consistently evidence that fair treatment of customers is at the heart of their business model.
But how do you evidence this without it becoming simply a tick-box exercise? Effective outcomes testing provides authorised firms with a valuable opportunity to not only improve relationships when something goes wrong, but also enables the firm the opportunity to proactively make changes that deliver good outcomes to all customers.
At Themis Consultancy we have developed methodologies which can help firms monitor and test that customers truly are being treated fairly.
The fair treatment of vulnerable customers has always been at the forefront of the FCA’s agenda, but never more so than now. The FCA has urged all regulated firms to review the FCA’s updated guidance on vulnerability, and expects firms to identify, understand and help vulnerable customers, and to update their policies and procedures accordingly.
As firms continue to deal with the need for forbearance arising from the Covid pandemic, there will be an even greater expectation on firms to consider the vulnerability of impacted customers.
Themis Consultancy has the knowledge, skills and experience to confidently assist firms in these challenges. Whether it’s a gap analysis against the updated guidance, a review of your vulnerability policy and procedures generally, or in response to the Covid pandemic, Themis Consultancy can guide and support you to ensure your vulnerable customers are identified and treated fairly.
We can also help train your customer service agents, so they feel confident when dealing with vulnerable customers.
A risk-based compliance monitoring methodology is critical to any successful governance framework and fundamental to meeting your regulatory obligations set out in the FCA’s Handbook (SYSC). Having products and processes independently monitored and tested in order to identify risk outside of established appetite will allow you to identify, minimise and mitigate potential compliance risks and reduce the potential for detriment to consumers.
At Themis Consultancy we have unrivalled experience in creating new or reviewing existing monitoring frameworks, to help give you peace of mind when it comes to meeting regulatory expectations and meeting your obligation to act in the interest of customers (PRIN).
Targeted Compliance Audits
Everyone at Themis Consultancy knows that when you undertake an audit it can feel like a painful process. However, we aim to make it thought provoking, inclusive and positive. We believe we have the ability and skill to make any targeted and comprehensive review of a firm’s adherence to regulatory obligations progressive and rewarding, by evaluating the strength and thoroughness of policies, procedures, controls, oversight and governance and working with you to make improvements.
We can also assist with Past Business Reviews (PBRs), whether it’s something you want to do as a matter of best practice, to satisfy investors or as a result of a FCA supervisory request. Our team has a wealth of expertise to support and conduct a PBR. As stated above will support you, providing assistance to analyse and test appropriate methodologies as required by you and which we believe will meet regulatory expectations.
At Themis Consultancy we don’t believe training should be dull or a tick box exercise. That’s why we aim to offer meaningful training, based upon scenarios and examples to test the knowledge, application and understanding of attendees. We can provide training via zoom, or eLearning packs covering a number of subject areas:
- SM&CR essentials
- Senior Management Responsibilities & the SM&CR
- Conduct and Culture Workshop
- Data Protection & GDPR
- Financial Promotions workshop
- ASA Complaints
- Financial Crime general
- Vulnerable Customers
- TCF and customer outcomes
General Consumer Credit Compliance Best Practice
The team at Themis Consultancy individually, and collectively, offer real business experience, knowledge and expertise to assist firms across a wide range of highly regulatory areas, including:
- COVID-19 forbearance strategy
In response to the COVID pandemic, the FCA announced specific guidance for firms to ensure tailored support for borrowers affected by coronavirus is delivered. Firms have been regularly submitting data to the FCA and we are now seeing firms being contacted by the regulator to demonstrate and evidence compliance with the guidance.
At Themis Consultancy we can review your application of the COVID-19 guidance so you can be confident your customers are being treated appropriately and fairly.
- Financial Promotions
Do you need help with your Financial Promotions (“Fin Prom”)? When is a Fin Prom not a Fin Prom? Do I need a Rep APR or a Rep example? Is that statement a trigger for the Rep APR? (excuse the jargon). We laugh but these are real questions that businesses often grapple with, and understandably so. Everyone at Themis Consultancy has asked themselves, or others, these questions and that’s why we have an abundance of expertise in this area. Whether it’s training on the regulatory requirements, guidance on interpretation of the rules, compliance management of a marketing campaign or help with an ASA complaint, get in touch today to discuss how we can help you.
- Collection of payments, recoveries and arrears
This area of any lending business is key, not only from a commercial perspective but also from a compliance and customer perspective. Ensuring the fair treatment of customers when making payments, including dealing with arrears is also a key regulatory focus. Get this wrong and the reputational damage as well as the potential regulatory censure could be high. The team at Themis Consultancy is extremely experienced in reviewing collections, arrears and forbearance strategies, and providing ideas and solutions which may support your business, secure compliance with CONC 7 and ensure customers are being treated fairly. Whether you need a basic review of existing policies and procedures or a full audit, we can help.
- Financial Crime assessments
How robust is your financial crime strategy? It’s an ever-increasing priority for the FCA and as the regulatory spotlight intensifies, so does the burden on regulatory financial services firms and individuals approved as the MLRO (SMF17). Themis Consultancy can help you conduct a one-off financial crime assessment, providing you with the guidance so you can be confident that you know what is required of your firm.
GDPR & Data Protection Practices
At Themis Consultancy we have expertise in data protection compliance, including and the General Data Protection Regulation (GDPR), the Data Protection Act (DPA) and the Privacy and Electronic Communications Regulations (PECR) to assist firms in meeting their regulatory obligations. Our advisory services cover:
- Data mapping
- Data Protection Policies & Procedures
- Privacy Notices/Policy for website
- Cookie Notices/Policy for website
- Data Protection/GDPR training for staff (face to face and e-Learning)
- Data Breach Management
- Data Protection audit
- Legitimate Interest Assessment
- Data Subject Access Requests
- Right to Human Intervention
Themis Consultancy has a proven track record of creating, reviewing and implementing wind-down plans within consumer credit regulated firms, to ensure any wind-down is planned and undertaken in an orderly manner, and in a way which reduces the harm to customers, other stakeholders and the markets.
We work with firms to create a plan to include associated risk frameworks, management information, early warning indicators and trigger scenarios so that firms are able to make timely decisions as to the appropriate course of action based upon their own risk appetite.
The team at Themis Consultancy can provide the right balance of knowledge and experience covering all the key aspects of a comprehensive wind-down plan, including compliance, governance, risk management and operational expertise.
Themis Consultancy Retained Services
The team at Themis Consultancy can provide ongoing compliance support to clients, and we will happily tailor our services depending on the size, nature and needs of your business. We offer a variety of retained services packages, subject to your needs. We appreciate that often firms have done much of their own compliance groundwork but that sometimes having a second pair of eyes, or someone to sense check and provide positive challenge may provide reassurance. Our retained services packages seek to provide exactly that and more. We will provide you with telephone, email and one to one support as required, on a bespoke basis, covering one or more of our core compliance services, which include:
- Guidance and support with compliance monitoring
- Support with targeted compliance audits, including assistance in designing 1st and 2nd line defence frameworks
- Bespoke guidance in relation to customer outcomes testing
- Policy reviews – including but not limited to vulnerability, affordability and creditworthiness, arrears and collections and financial crime policies
- Compliance training
- Support with complaints strategies and root cause analysis
- Independent audits
- Past Business Reviews
- Guidance on regulatory reporting
- SM&CR (including training)
- Regulatory updates
How we will support you
Access to an experienced, dedicated team who will develop an understanding of your business so that the advice and support provided can be tailored to your specific business
Expert perspectives on the areas of focus and priority from the FCA and its current approach
On hand support and guidance that is right for your business, with the flexibility to change it when your needs change
Regular feedback with open communication so you will always be up to date with progress
A 10% discount on our regulatory training courses and resources
Why Choose Themis
If you believe you would benefit from a personal, flexible service which offers you solutions- focussed advice and support, from a team of professionals who will take the time to understand your business and tailor the support to suit your needs, then please contact us.