Case Study 3
FCA mandated and internally driven projects, requiring the Bank to address historical account management issues which have led to customer detriment.
The Bank was required to put in place fair remediation for customers and ensure appropriate actions taken to rectify root causes of any issues identified.
Coupled with the delivery of remediation, Capital and IFRS 9 impairment impact analysis was also required to ensure reporting and model impacts were fully understood, and where appropriate, regulatory notifications made.
Managed the end to end governance and delivery of downstream impacts to Capital and IFRS 9 impairment (for actuals and forecasting) across the various remediation projects, including ongoing support for BAU Model Calibration processes.
Worked with business partners across functions to ensure broader credit risk impacts were identified and appropriately managed, including Collections & Recoveries, Legal, SOX controls, impairment finance, reporting systems administrators and beyond.
Prepared and delivered PRA notifications and appropriate supplementary materials, dealing with any follow-up queries from the regulator. Supported product owners with developing principles for remediation, data interrogation and validation of customer outcomes.
Data-driven integrity checks and monitoring resulted in a number of issues in the implementation design being identified and resolved before any adverse impacts could be passed to customers, enabling the Bank to fully comply not only with regulatory commitments but also prevent unintended negative customer outcomes.
Using test data we were able to develop methodologies which allowed us to accurately predict and track prudential and impairment impacts for both regulators and business stakeholders (both before and after remediations took place).
We have supported the Bank with the delivery of over half a dozen flagship retail rectification projects.