Client background 

Our client was a UK-based, regulated entity providing mortgage underwriting services, mortgage servicing operations and risk, investment, capital markets and other support and management services to the wider Group and third parties and employing c.600 people globally.

The challenge 

The firm was asked to produce a Wind Down Plan by the FCA based on the most recent regulatory rules and guidelines which could be presented to the Board, to be delivered to the FCA within a challenging timeframe.

The client wished to identify the most appropriate wind down scenarios, triggers and recovery options and to improve preparation, forward planning and understanding of an orderly wind down across senior management and department heads.

Our approach and contribution 

Working in close partnership with the Chief Financial Officer and a Finance representative, we:

• Undertook analysis of existing documentation, policies and procedures.

• Co-ordinated and led introductory workshops to wind down planning, expectations and actions with all departments.

• Reviewed, proposed, discussed operating costs and revenue income in the event a wind down is triggered; produced appendices to substantiate numbers / headcount.

• Held weekly status updates with the accountable executive or representative to ensure progress was timely and issues could be addressed swiftly.

• Produced a line-by-line GAP Analysis document which assessed the firm’s compliance to the latest regulatory Wind Down Planning rules and guidelines.

• Identified gaps and proposed enhancements or actions as appropriate.

• Held reviews at regular intervals of the GAP Analysis to provide assurance to the client the delivery was on schedule and would meet necessary regulatory standards.

• Produced a final Wind Down Plan document.

The outcome 

• As a result of our engagement, our client was able to: 

• Present the Board with a new, robust Wind Down Plan within the challenging timeline.

• Be assured the document and processes reflected most current regulatory requirements.

• Ensure a broader range of senior management and department heads understood the requirements, concept and processes should a Wind Down be triggered.

• Deliver the Wind Down Plan to the FCA within their timeframe and following their review, receive confirmation that the outcome was satisfactory.