After assessing the risk management operation of a FTSE 100 company we soon identified that Operational Risk Management needed augmenting on their global risk framework. After 10 months work the savings were reflected in the reduction of regulatory capital requirements of over 18% (almost £100M).

1. By Doing What We Designed for a FTSE 100 Company

2. In The UK Financial Services World, as it is across
Europe, Regulatory Capital is calculated across the
three pillars or the Internal Capital Adequacy
Assessment Process.
The main findings of the ICAAP analysis are:
how much and what composition of internal
capital the firm considers it should hold as
compared with the capital resource
requirement (CRR) ‘pillar 1’ calculation,
and the adequacy of the firm’s risk
management processes.

3. The Capital Resource Requirement (CRR) is the
result of the Pillar 1 calculation and is mainly fixed
overhead based, including winding down costs of
the business or parts of it. Apart from accountancy
efforts and a costs moratorium, there is little to be
done to assist in this area from our perspective as a
risk and compliance consultancy.
• However, where we score and can make a big
difference is in the adequacy of the firm’s risk
management processes.
• We saved a firm almost 20% of their
Individual Capital Guidance (ICG)
by helping define their risk
management package

4. • Implement a fully operational and effective risk
governance structure enabling the timely
identification, mitigation and reporting of the group’s
key risks along the chain of management up to the
Board of Directors
• Design and execute on an integrated control
environment coordinated across all support functions
to optimise the balance between efforts dedicated to
controls improvement and areas of risks.
• Achieve the consistent integration of the
risk tools and methodologies in the
firm’s financial processes to inform the
firm’s strategic decisions and ensure
that the group remains within its risk
appetite across all risk categories

5. • The Credit Risk system needed urgent upgrading to
take in all global feeds and be tested against the BCP.
• The risk identification and monitoring system required
significant re-structuring to remove the one
dimensional aspect of the risk reporting to a multilevel COSO cube based structure – a challenge with
the existing software (that had recently been
relicensed and increased functionality applied).
• The Firm’s Risk Appetite needed to be clearly
identified across the various risk categories and
divisions to provide a clearer point to measure
vulnerabilities and prioritise risks for
mitigation action. The original method
of risks were confused combined were
cumulative in their assessment when
the impact should have been totalled.

6. • The two risk consultants analysed the current risk
database and quickly identified the single facet to
the risks, calling for a complete overhaul of the
list of potential standard risks on a triple layered
standard, providing Management Information to
the required level in a robust, consistent and
appropriate standard.

7. • Identification of the risks then provided a clearer
and more accurate risk reporting regime which
once identified could then be plugged into the
entire business, creating business type specific
scenarios for risk assessment purposes, feeding
into the ICAAP calculations.
• This then provided an overall and measured
risk assessment that provided quantifiable
losses over previous qualitative measures.
• This had the benefit of saving over
18% of the regulatory risk capital
requirement
• Translating into almost £100M!!!

8. • Total time spent 10 months.
• Resource Cost 5.3% of savings over 1 year.
• Resource Cost 1.06% of savings over 5 years
• Internal Cost approx. £350,000
• Senior Management sleep value - priceless

9. • There is more likelihood of your privacy
and confidentiality being observed with
fewer people working on the project. We
(and/or the few people we might also involve)
are constant which means that there isn’t the
need to sift through dozens of differing
perceptions.
• We’re faster. We can respond to requests
quickly, and return all calls within four hours
which means to you that there is no need to
worry about a bureaucracy, delays and
unknown people on the other end of the
phone

10. • Since we handle fewer concurrent projects than
larger firms, our attention is focused on the job at
hand. This means that you don’t have to
"compete" with another dozen or so of our
clients, which may be larger, paying more or are
more time-demanding. We structure our work so
that every client receives maximum
attention.
• Your investment is controlled. There is no
"meter running". We work for a fixed, valuebased, project fee. Large firms can’t afford to do
that as readily because of all the people involved
and their own insistence on measuring their
success by billable hours. We measure our success
by client objectives reached, not in “time units”.

11. • The expertise that larger firms use is often whitelabelling for them by a pool of consultants
available in the marketplace at any one time. We
select our consultants from practising
subject matter experts which means that
you obtain the same or better expertise for less
money, because;
• Inevitably, we are less expensive. There
are economies to using someone who can base
their fees on each situation and not on a predetermined service scale or need for reaching a
practice quota. This means quite simply better
value to you.

12. • You are always dealing with the principal when
you are dealing with my firm. This means that I am the
relationship manager and there is no junior partner to
whom responsibility will be transferred. There is no
decreased accountability, no "hand-off" to a lessinformed colleague. If your interests are at stake
continually, shouldn’t you reasonably expect my
continual involvement?
• We can usually provide resources on a "just in
time" basis. That is, our projects do not have to cover
excessive overhead, such as multiple offices, large
administrative backup, recruiting, partner perks, etc.
We are organized to efficiently provide everything that
you, as the buyer needs, but nothing more than that
which means that you are paying for value and results
and only minimum overhead.

13. Click Mouse Reveal Next Phase
Phase 1
We will conduct an initial appraisal at our cost
– only charging for expenses
Phase 2
We will make a proposal based on our
appraisal with your outcomes and needs
Phase 3
We will discuss the precise scope with you
and provide you with a project price
Phase 4
We will complete the work to your original
scope and satisfaction

14. We have a wealth of Financial Services Experience, and due to
the remedial and sensitive nature of our work forming over 60%
of our business and that is conducted under a Non Disclosure
Regime, we cannot demonstrate every client.

15. We Do have a large
amount of experience in a
number of other fields and
industries within the major
utilities and even Local
Authorities.

16. We can provide all manner of assistance in
• Initial risk assessment or audit — an initial analysis to
identify higher risk areas of the business and weaknesses
in procedures. We also do risk management design.
• Business development — business analysis advice or
advice on particular issues — for example, how your firm is
Treating Customers Fairly and an action plan for
implementing Conduct Risk across your business.
• Help with setting up procedures — for example procedural
manuals for recruitment, training and competence,
complaints handling and anti-money laundering. May also
include templates for disclosure documents, fact-finds and
registers.
• File audits — checks to ensure that procedures are being
followed and identify good practices and weaknesses
• Complaints Handling – cost effective and project managed
from start to finish making your response robust and
consistent

17. • Technical support — may include advice on particular
products or regulatory reporting. May be available in
various formats, including website, helpdesk and
individual technical advice.
• Training — for example competency assessments,
training opportunities or product risk guidance. May
be online support, regulatory updates or seminar
based.
• Support on individual issues — for example in
dealing with a complaint, a financial promotion or a
particular suitability letter.
• Financial promotions (all areas of advertisement) full support which would include websites, brochures,
DVD's, email templates, client mail shots, adverts,
contacting existing clients and so on.
• Remedial work — helping to action remedial work
required by the FCA/PRA.
• And much more … just ask!

18. CEI Compliance Limited
www.cei-compliance-limited.co.uk
Tel
07801 964980(UK)
Tel +44 7092
289901 (Int)
We operate across the UK, Europe
and the Middle East.
Currently exploring opportunities in
Latin America