PAST BUSINESS REVIEW

Firms looking at taking remedial action may have to conduct a Past Business Review (PBR). If a PBR is appropriate firms tend to face a number of challenges. These fall under three main headings: Resource, Process and Systems and are explored below.

The Right Resource

Any resources employed to carry out the review must meet a minimum standard of competence. They should be able to demonstrate knowledge of the mortgage market, objectivity and impartiality in decision making and sufficient experience to be able to apply a balanced approach to interpretation of the customer file. Sourcing and assessing the suitability of appropriate resources from scratch can be a daunting task.

The Telos Compliance service follows a rigorous assessment process to accredit PBR resources. This not only includes a written file review assessment but also a structured interview which helps us to understand the depth and application of knowledge by the individual.

Process

The process followed needs to be consistent and take into account all stages of the review, population identification and case selection, investigation and review, assessment of causation and finally remediation where customer detriment has occurred. There will also need to be regular reports on progress and a final report on trends identified and any further actions which should be carried out.

Telos has drawn on their wealth of experience to develop an end to end process for the delivery of a successful PBR. The tried and tested process encapsulates all of the elements described above and ensures compliance with DISP and SYSC. It also provides confidence to the firm and FSA alike that a consistent approach will be applied.

Systems

Invariably every firm has a different record keeping system. It is important that the results of each individual case review can be recorded in a structured format to allow for ease of reporting and trend analysis. The system also needs to be able to track the progress of the review and any further remediation process to its conclusion. Firms will also want to know that the standards being applied are consistent across the industry.

The Telos Compliance system is based on a market standard case management tool, which and has been specifically configured to capture salient information about all of the cases reviewed, can maintain copies of documents and provides an audit trail to show all stages of the review and remediation process. It produces regular reports in a standardised format and allows for detailed trend analysis to take place. Data can be extracted to populate remediation calculations and the results of these can be captured to facilitate account reconciliation.

Telos has invested substantial time to develop a series of tools to simplify the above processes. By engaging with the Telos Compliance service firms can be confident that any PBR carried out will meet the exacting standards required by the FSA, and will be impartial and pragmatic.