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Compliance Consultant – Section 166

Section 166 reviews are one of the most powerful tools the FCA has to try to correct the actions of Financial Services organisations who they have concerns about. Section 166 gives the regulator the power to require a “skilled person” to carry out an independent review of a business.

An established Consumer Credit firm reached out to Kind Consultancy for support to help them work with the regulator following a Section 166 notice being issued.  The client had not worked with Kind before but were aware of our reputation for Interim Compliance resourcing. We met with their Head of Compliance and discussed the situation and their needs in detail – in their case the FCA had asked them to appoint the skilled person themselves.

We then providing them with one of an experienced Compliance Consultant from our Kind Agile Solutions bench, to work with the senior management team on the appointment of an FCA approved Skilled Person. We work with a number of Compliance SMEs and we knew this situation required someone who had previously completed Section 166 reviews, and also had experience of guiding a business through large scale remediation projects based on the recommendations arising from an S166.

The review required an assessment of more than 4,000 customers over a period of 5 years, so in addition to our Compliance Consultant, we also supplied a number of Compliance, Collections and Credit Risk professionals to complete the necessary appraisal in time.

We achieved the confidence of the FCA and a successful remediation project through detailed remediation methodology documentation, accurate and timely reporting, the demonstration of structured planning, and effective 3 lines of defence activity.

Head of Compliance – SMF16

Head of Compliance is the most senior Compliance title in most Financial Services organisations – and as such recruiting the right one is of the utmost importance in running a successful regulated business. Holding the SMF16 senior management function means that Heads of Compliance are the individuals with overall responsibility for ensuring their firm is fully compliant with all regulatory requirements.

Kind Consultancy was approached by the Chief Risk Officer of a growing challenger bank which was seeking to identify a new Head of Compliance following the previous incumbent moving on from the business.

The Kind team had a face-to-face meeting with the CRO, taking a full brief of the role and building an understanding of the expectations for the Head of Compliance as an individual and how they fit into the bank’s wider business plans. We used all of this information to help the client draw up a detailed role profile.

We then set to work utilising a mix of methodologies to map the market and identify a list of relevant individuals who met client specifications and were at the top of their game in Compliance, including individuals currently holding the SMF16 responsibility at some of the bank’s closest competitors and other comparable organisations.

The Kind team confidentially approached these candidates, and discussed their experience and skillset but also their individual motivations and long term career aspirations – making sure we were only moving forward with candidates who had held SMF16 and wanted to do so in their next role. We submitted a shortlist of 4 candidates who had the relevant expertise, but who we also knew were personally aligned with the values and goals of the bank.

We supported our Head of Compliance candidates and the client throughout the interview process, and following a second stage interview an offer was made to and happily accepted by one of our candidates. We continued to check-in with our candidate and client, throughout their probation period to ensure both parties are fully satisfied with the placement.

Compliance Monitoring Manager

Compliance Monitoring Manager is a crucial title within a Financial Services firm’s Compliance function, with oversight of the assessment of how well Compliance policies and procedures are working in the business’s day to day activities.

A growing challenger bank approached Kind Consultancy with a need to recruit a permanent Compliance Monitoring Manager as they expanded their Compliance team. Monitoring responsibilities had previously been handled by their Compliance Manager, and they were now at a size where a dedicated Monitoring Manager was required.

They had previously attempted to fill the role themselves and had been turned down by the two candidates that they had offered the position to. The bank’s headquarters are not in a major city, and the location had been a dealbreaker for both of their past candidates.

We took a full brief on the job and the long-term plans for the business, and contacted a number of Compliance Monitoring professionals who were already part of our extensive database of Compliance talent, as well as confidentially approaching some Compliance Monitoring Managers who were at the time working for similar sized challenger banks. We made sure that any candidate we considered shortlisting was open to commuting to the office location.

Selecting the people from both sources that we felt had the necessary skills and experienced and were personally aligned with the bank’s long term plans, we submitted a shortlist. Shortly after interviews were conducted, the client offered one of our candidates who happily accepted.

The candidate unfortunately then faced a number of complications and delays in their relocation, and they were unsure they would be able to start the role.

Staying close to both candidate and client, Kind were able to devise and suggest an arrangement where the candidate would come on board immediately as a contractor working remotely, and would then be taken on permanently once the relocation was completed. Both parties were happy with this solution, and the selected Compliance Monitoring Manager candidate was screened and on-boarded as a contractor in just a few days.

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A specialist recruitment and executive search firm specialising in interim and permanent Governance, Risk, Compliance, Complaints, Financial Crime and Change & Transformation roles across Financial Services

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