Our Board is committed to high standards of risk and regulatory management. We operate a ‘three lines of defence’ model ensuring that we are able to monitor and proactively manage risk; allowing us to respond swiftly to any identified issues
- 1st line - provided by the business functions, which have primary responsibility for implementing key controls for identifying and managing regulatory risks, ensuring on-going compliance, and monitoring their effectiveness.
- 2nd line - provided by our compliance function who are responsible for monitoring, reporting and providing advice to our business functions.
- 3rd line - provided by our internal and external audit teams and offers independent assurance that the processes and controls in lines 1 and 2 are appropriate and operating effectively.
The Risk team are responsible for developing risk awareness, managing and reporting on risks and providing guidance on appropriate risk management strategies.
A monthly Risk & Audit committee provides the day-to-day governance of risk. Appropriate records of risk management activities are retained in the form of Risk & Audit Committee minutes, supporting documentation and include data recorded on Target’s Risk Management system
Our Compliance function is divided into three key areas:
- The Advisory Team provide advice & guidance to the business via service desk requests and project support to ensure all staff are conducting business in a way that is compliant and that ensures fair outcomes for consumers. The team review and approve operational policy & procedure, letter suites, training material and system changes/testing to ensure regulatory compliance.
- The Regulatory Development Team continually monitor developments within the industry and produce compliance bulletins and regulatory alerts to assess impact to clients and address any regulatory/industry change.
- The Financial Crime team provide oversight & support relating to financial crime matters to the operation. Responsible for dealing with all aspects concerning financial crime including money-laundering & terrorist finance prevention, sanction checking, anti-corruption policy and fraud management issues.
Monitoring and Audit Functions
The Risk & Compliance monitoring plan is set on an annual basis with a degree of flexibility built in to accommodate any emerging issues.
We utilise a number of monitoring techniques in our approach to compliance monitoring, including regular monitoring, thematic reviews and ad hoc monitoring checks.
Internal Audit follow a risk based annual audit programme approved by the Board. This ensures appropriate coverage of operational and support areas including a focus on information security and regulatory adherence. Internal Audit management of the closure of audit findings and significant matters are escalated to the Risk & Audit committee as appropriate.
Authorisations & Accreditations
Our servicing division is authorised and regulated by the Financial Conduct Authority, number 454569 and we have the following authorisations:
- Administering and arranging a regulated mortgage contract – customer
- Administering and arranging a home reversion plan – customer
- Arranging deals in investments – Professional/Retail
We also hold the ISAE3402 (SAS70) accreditation.