5. Be More Swan: Practical steps for a sustainable solution: Deliver
In this edition of our Regulatory Change mini-series we look at three effective steps in the delivery of Implementing Regulatory Change which form part of the 9 step framework to ‘Be More Swan.’
Invest in strategic flexible delivery capabilities to manage unpredictable workloads and changes in direction, whilst driving cost efficiencies.
Build a flexible regulatory resource pool
Coordinate and plan client engagement
Create a regulatory processing factory
4. Build a flexible regulatory resource pool
We have found that a formalised flexible regulatory resourcing model, with three tiers of resources, provides the ability to switch resources ‘on’ and ‘off’ at short notice. This is important to provide the ability to reliably hit short -notice deadlines, avoid burn-out of staff and avoid unnecessary costs of unproductive resources.
This requires proactive investment to set it up, a dedicated talent strategy and effective ongoing management.
Tier 1: Dedicated departmental SMEs
- Subject matter experts from each key department involved in regulatory change implementation.
- Formally dedicated (at least in part) to the programme.
- Responsible for day-to-day representation and management of their area.
Tier 2: Transferable internal programme resources
- Internal pool of expert project and programme managers, business analysts, data analysts and IT resources.
- Fully understand the organisation’s method for delivering regulatory change.
- Specific regulation expertise not necessary.
- Ability to be swiftly deployed onto new and varied regulatory change initiatives.
Tier 3: Scalable external resources
- Flexible capacity and capability with external consultants and contractors.
- Used for specific discrete items of work.
- Provides the ability resource up for intense periods or for projects requiring particular skillsets.
5. Coordinate and plan client engagement
A dedicated global client outreach workstream tightly linked to the other parts of implementation, allows clients requests to be joined up and managed, including during changes of direction.
Regulatory change initiatives typically require firms to obtain a substantial amount of information about, or obtain additional legal agreements with, their clients. Often, obtaining the information will only be the first step, with regular ‘refreshes’ of information required.
In most situations, several projects (potentially originating from different regulations, from different geographies, and/or from different parts of your organisation) will need to interact with the same clients, meaning a dedicated coordination function is vial.
Client engagement checklist
A single point of contact for each key client to avoid forcing clients to manage internal organisational and functional boundaries.
A client outreach strategy (e.g. support and coordination arrangements, the approach per asset class, jurisdiction etc.).
Coordinated high quality client communications with clarity of options for each regulation.
Clients’ expectations managed: regular progress updates, no over-promising and under-delivering, a forecast of likely future requests.
A maintained and regularly updated central client contact system, built into KYC.
An IT planning methodology that is flexible enough to manage the frequent changes in direction.
Clients contact and responses tracked to allow management information and an audit trail.
6. Create a regulatory processing factory
Investing in setting up a ‘processing factory’ allows data, due diligence or legal agreement processing tasks to be turned into a production line that makes resource planning easier, drives cross-functional productivity and, in many cases, allows the tasks to be handed to cheaper, commoditised resources.
Every regulatory change implementation inevitably involves routine and repetitive processing of large volumes of client and internal data, often at short notice, and also often with a cross-functional coordination challenge. The ability to respond robustly and flexibly is very important.
An effective production line needs a well-defined work package to scope its task. Multiple production lines will likely need to exist in parallel. A project management function overseeing the activity is thus helpful.
In the next edition we explore the final of three editions on the Gate One Be More Swan framework in “Practical steps for a sustainable solution: Control”