Emma RadmoreLSB has stressed the importance of governance as underpinning everything a firm does, and has started a series of publications to help firms. Its latest guidance looks at how to achieve best practice. The guide stresses:
- the importance not only of doing the right thing by customers, but also of being able to show you have;
- the need for clear policies and processes, setting out the firm’s approach to the various stages of the product and customer journey – explaining, for instance, things like how support will be given to vulnerable customers following the written vulnerable customer policy;
- the importance of both ownership of policies and procedures and the frequency of reviews;
- how risk management frameworks should give senior management a view of the risks facing both the firm and customers, with the steps being taken to mitigate them – and how risks evolve so that the framework needs constant monitoring. It notes how firms can learn from things that go wrong, and use these to improve their risk identification and management;
- how breach logs can help;
- the key role of MI, which captures what is needed and can be produced using the information that is required;
- change management, which will form a central part of helping new market entrants to deliver better outcomes – and that firms should make sure the right departments are involved in all stages of evolving product design; and
- how complaints, also, can provide an opportunity to learn – and the importance of making sure that root causes are addressed and, if the cause is a process failure, the importance of engaging with the process owners.
