#CP86

#CP86Solution

Objectives:

Short-term:  

Ensure you are fully prepared for an on-site inspection by the Central Bank of Ireland that results in the best possible outcome for your firm across people, processes and profitability. 

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Long-Term: 

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Ensure your firm has a solid foundation to build upon while improving your ongoing relationship with the Central Bank.

#CP86Solution

#CP86Solution

Outcomes:

Fund management companies that engage the CP86 Inspection Preparation Advisory will:

1. Know what to expect when the Central Bank performs an inspection with more than 80% accuracy 

2. Be prepared for and perform better in interviews with the Central Bank

3. Understand the Central Bank’s perspective on CP86 and its areas of focus so you can compare and contrast those with your firm’s current situation

4. Understand where your areas of weakness are in your documentation and/or operations so you can prioritise and action problem areas in advance of an inspection 

5. Work hard to improve your relationship with the regulator

#CP86Solution

#CP86Solution

Value:

Fund management companies that undertake the CP86 Inspection Preparation Advisory will gain value in four key areas from hour one. 

Business Continuity: 

Being prepared for an on-site inspection facilitates the highest probability of business continuity with existing clients, potential business and you and your firm’s industry reputation

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Reduce: 

1. the likelihood of costly regulatory fines and damaging public sanctioning

2. the stress involved with being subjected to a regulatory inspection

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Optimise: 

1. Your relationship with the Central Bank to be in the best possible position now and well into the future

2. staff retention, company productivity, morale and culture by clearly demonstrating management’s support for them in what can be an intensely stressful time

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Independent Voice of a fund lawyer and ex-regulator who co-authored CP86

To reinforce the messages where change is necessary but continues to be resisted by HQ

#CP86Solution

Phase 1

Setting us up for success

Intake form issued: a set of questions to be completed in advance of  our first on-site meeting

Inspection Process Overview issued: a document shared with you to review in advance of our first on-site meeting

Inspection Preparation Timeline issued: a document shared with you to review in advance of our first on-site meeting

Execute our mutual NDA 

Completed CB Questionnaire - Documentation submitted to the CB to be shared with Aquest by the end of our first on-site meeting

Lay of the Land meeting scheduled with all relevant firm stakeholders

#CP86Solution

PHASE 2

‘Lay of the land’ workshop

On-site meeting with Daniel Lawlor to explore the: 

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1. fund management company’s preparations provided to the Central Bank 

2. understand the concerns that the fund management company might have, 

3. share the concerns Daniel Lawlor has about the current situation

4. ensure full clarity of what the inspection process will involve and the likely outcomes

5. devise a plan to ensure that the fund management company uses its preparation time effectively during and after the CP86 Inspection Preparation Consulting service.

#CP86Solution

PHASE 3

Full Analysis of your Submission

Daniel Lawlor will analyse your entire submission to the CB before providing you with a full report on what you can expect when they are inspecting.

Daniel Lawlor will undertake a review of the completed Central Bank questionnaire and supporting documentation submitted by the fund management company to the Central Bank for the desk-based review. 

The formal report will provide a clear picture of the fund management company’s

• strengths

• weaknesses

• red flags

Daniel will highlight the areas; 

• most likely to be questioned during an inspection

• potential areas that may be questioned during an inspection

• that will strengthen and support your position

#CP86Solution

Phase 4: OPTION 1

Full day on-site workshop 

Daniel Lawlor will spend a full day on-site with the fund management company’s leadership team. 

There are 2 options for how to structure your day: This will present option one. 

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OPTION ONE:

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1-hour briefing session on CP86 to Designated Persons and Directors to cover:

Background & rationale for CP86

Summary of key contents of CP86

PRISM & the CB's approach to supervision & inspections

The CB's CP86 inspection process and key areas of focus

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Up to x6 1-1 ‘mock’ interviews lasting 30 minutes each w/ Designated Persons & Directors conducted by Daniel Lawlor assuming the role of a CB inspector. 

CP86 Preparation Workshop

Feedback on interviews: strengths, weaknesses and red flags

Insights on CP86-related areas that the CB are likely to focus on

Insights on general legal and regulatory matters that the CB are likely to probe further

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How to use your time to prioritise actions in preparation for an inspection

#CP86Solution

PHASE 4: OPTION 2

Full day on-site workshop

Daniel Lawlor will spend a full day on-site with the fund management company’s leadership team. 

There are 2 options for how to structure your day: This will present option two.

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OPTION TWO: 

3hr CP86 Process Workshop: 

CP86

Context for a CP86 inspections

Fund manco ecosystem

Post CP86 developments

CP86 areas of focus for your firm specifically the dominant Overarching themes

Regulator mindset when conducting inspections with your firm, specifically in light of your submission

How inspections are conducted in practice and then specifically what you can expect based on your submission.

How regulatory inspections fit into the PRISM model of supervision:

Types of inspections

Inspection process

Outcome

Likely output from CP86 review process

Next steps

Practicalities of preparing for an inspection

Pitfalls and common mistakes

Tips based on your submission to the Central Bank of Ireland

Fund Management Company and CP86

Overarching impressions following review of the fund management company’s documentation 

Any significant/obvious gaps identified in CP86 compliance

Areas that the Central Bank is like raise focus

Approach of peers

Interactive Q&As throughout the session

2.5hr  CP86 Preparation workshop: 

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tease out any areas of weakness issued identified in the interactive session and brainstorm how these can be addressed; and 

discuss how the Designated Persons, directors and Organisational Effectiveness role are carrying out their roles in practice, understand the regulatory expectations around how these roles should be carried out and address any concerns or issues arising 

#CP86Solution

PHASE 5

Support during an inspection

Should you be inspected by the CB in regards to CP86, Daniel will provide you with active inspection guidance to support your firm in how to best navigate the process while simultaneously working with you to improve your relationship with the regulator.

#CP86Solution