FRSGlobal
Conduct Risk
and the FCA:
What’s your next move?
www.wolterskluwerfs.com
Conduct Risk and the FCA:
What’s your next move?
This paper provides an overview and, to some extent a prediction, of what
life will be like for firms under the supervision of the new Financial Conduct
Authority and will consider some of the key components of an effective
approach to Conduct Risk. It is based not only on what the FSA are saying,
but also on the current responses being developed by a range of firms across
the financial services spectrum.
It will be of interest to the Board, Executive Committee and senior
management team as well as to risk, compliance and audit functions within
firms. Whilst Conduct Risk is a particular concern to firms regulated by the
FCA, this paper will also be of interest to all firms who operate in the UK
regulatory environment and to subsidiaries and operations of UK based
businesses operating in other jurisdictions.
FRSGlobal
Conduct Risk and the FCA:What’s your next move?
Definition – What is Conduct Risk?
A good starting point for thinking
about Conduct Risk, and crafting
your firms own definition of, and
framework for managing, Conduct
Risk, is the FSA’s Core Conduct
Programme which was rolled-out by
the FSA as its main supervisory tool
to assess conduct. It covers five core
areas which will be considered in more
detail throughout this paper.These are;
Business Model
Culture, Governance & Controls
Product Development &
Approval
Sales
1. Business Model
“When we consider authorising a firm, we
will look at its business model to ensure it
meets the needs of consumers and does
not place them, or the financial system as a
whole, at undue risk. We will balance these
high standards with allowing innovation and
appropriate access to the market by new
firms.”
Martin Wheatley – Journey to the FCA
So what do firms need to consider as regards
the business model? The FCA will expect
firms to be able to provide very clear answers
to the following types of questions;
What is the target market for the firm’s
products and services?
How does the firm identify, understand and
test the needs of the target market?
How does the structure of the business
ensure that their customers’ needs are at
the heart of the business?
How does the firm identify potential
conduct risk?
How are the needs of the customer
considered in the distribution model for the
business?
How will the firm ensure that the assets of
the clients are protected?
l l l l Post Sales Handling
2. Culture, Governance and Controls
2.1 Culture
Public trust in the financial services industry
(and in those who regulate them) is widely
considered to be at an all time low. Trust
is very hard to earn, extremely fragile and
easily shattered. Whilst many firms complain
that they have been tarred with the same
brush as those which have more blatantly
breached the consumers trust, for example
by continuing to sell payment protection
products long after the alarm bells started
ringing, they too will need to regain the trust
and confidence so badly damaged by the
perceived conduct of the wider industry.
Barclays is a good example of a firm that has
gone very public in its attempts to change the
culture of the business.
“For our Values to have true meaning,
employees need to live and breathe them.”
Antony Jenkins – Barclays Group Chief
Executive (Jan 2013)
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So how will the regulators measure and
assess the culture of a firm? The FCA will
approach culture by considering a range of
questions such as;
Do management model good behaviour, i.e.
make their values ‘live’?
Do management articulate a clearly
understandable strategy?
Do management offer guidance and
training to assist in good decisionmaking – for example, on ensuring the fair
treatment of customers and effective risk
management?
Do management incentivise good
behaviour and deter poor behaviour - and
how?
Do management encourage the required
diversity to facilitate challenge to ‘groupthink’?
Do management articulate their vision of
the right culture?
l l l l l So from the boardroom to point of sale
and beyond, firms’ behaviour, attitudes and
motivations must be about good conduct
– especially in terms of the experiences
and outcomes they offer their customers
and clients, whether it is someone buying
a basic product or completing a complex
transaction.
Martin Wheatley – Journey to the FCA
2.2 Governance
The Board
The Chief Executive Officer, Board and Senior
Management must recognise the importance
of their roles in ensuring the fair treatment of
customers and effectively managing Conduct
Risk. The FCA will expect to see evidence of
senior management commitment to the fair
treatment of customers.
All staff are trained and made aware of
the Conduct Risk and customer treatment
policies and their obligations under
them, and procedures exist to implement
appropriate training and awareness;
They understand and can articulate the
Conduct Risk Appetite of the business.
l l Customer Committees
Many large firms, particularly those with
a substantial retail customer base, have
established a senior forum with oversight
of all aspects of conduct risk and customer
treatment. Membership of these committees
will typically include senior representatives
from sales, customer service, complaints,
product development, legal, risk and
compliance functions as well as individuals
with specific Conduct Risk responsibilities.
l It is highly unlikely that the FCA will prescribe
what values and ethics should apply to any
given firm. This is all but impossible. But firms
should be under no illusion that they will be
closely scrutinised in this regard. And they will
need to be able to demonstrate to the FCA
that they have the right culture and values
and that employees ‘live and breathe them’.
In particular, as well as establishing a culture
within the firm which ensures the fair
treatment of customers, the senior team
will be expected to ensure that;
Conduct and customer treatment risks are
identified and effectively managed;
All business units within the firm have in
place appropriate policies, procedures,
systems and controls to manage Conduct
Risk;
Senior individuals, at group and business
unit levels, have the necessary resources
and influence to oversee and enforce
adherence to these Conduct Risk and
customer treatment policies and
procedures;
l l l It is highly unlikely that the FCA will prescribe what values and ethics should
apply to any given firm. This is all but impossible. But firms should be under
no illusion that they will be closely scrutinised in this regard. And they will
need to be able to demonstrate to the FCA that they have the right culture
and values and that employees ‘live and breathe them’.
4
Typically, the role of this Committee will
include:
Approving the Customer or Conduct Risk
Policy, and reviewing any substantive
amendments from time to time, prior to
presentation to the Board for final approval;
Receiving, considering and acting upon
relevant customer treatment and Conduct
Risk management information;
Reviewing the suitability of recruitment,
training and awareness requirements as
they relate to Conduct Risk; and
Reporting to the Board and Senior
Management on significant issues or
concerns under this Policy, as needed.
l l l l Conduct Risk and the FCA:What’s your next move?
Individuals’ roles and responsibilities
There is no specific FSA or FCA requirement
for firms to appoint a ‘Conduct Risk Officer’
or equivalent and firms have adopted a
variety of approaches. Whilst some firms
still use the Risk or Compliance functions to
oversee Conduct Risk, as the subject impacts
so many different areas of the business, more
and more firms have appointed a very senior
individual to lead and oversee all Conduct
Risk and customer treatment activities across
the firm.
Management Information requirements
Evidence of effective management of
Conduct Risk is of critical importance.
The specific content of the management
information will vary from firm to firm but
for many the FSA will expect to see many of
the following subjects covered;
Conduct Risk training performance;
Conduct Risk Incidents and outcomes/
recommendations for change;
Breaches of Conduct Risk Policy, remedial
actions and root cause analysis;
Treating Customers Fairly management
information;
New Product Approval and Product Testing
Management Information
Complaints Management Information; and
Reports of any Conduct Risk monitoring
activity or external reviews or audits
Conduct Risks will also change from time to
time so the Conduct Risk Assessment will
need to be regularly reviewed and refreshed.
Figure 1 below sets out an approach to the
identification of Conduct Risk and illustrates
how firms might use the Risk Assessment to
form the basis of their approach to;
Designing controls;
Implementing appropriate monitoring; and
Creating meaningful and actionable
management information.
l l l Figure 1: how firms might use Risk Assessment
Identify
potential
Conduct Risks
l l l The challenge for many firms will be
making sense of, and drawing appropriate
conclusions and actions from, the sheer
volume of data that a Conduct Risk
Assessment will generate. Large firms will
need to consider whether this is done on a
business unit basis or whether it makes sense
to aggregate the data and address the risks in
a consistent way across the wider group.
Action on
actual and
potential
Conduct Risks
Identify
potential
risks to TCF
outcomes
l l l l 2.3 Risk Assessment and Controls
As with any significant risk, firms must put
in place a process to systematically identify
the potential Conduct Risks and risks of unfair
treatment of customers across all products
and business units throughout the product
lifecycle. These risks may well be different, for
example, for the same product distributed
through different channels or to different
target markets.
Review of
Conduct
Risk MI
Identify actual
Conduct and
TCF Risks
Identify
Conduct Risk
reporting and
MI
Identify
Conduct Risk &
TCF Controls
Identify
Conduct Risk
Monitoring
Articulate
Conduct Risk
Appetite
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3. Product Development and Approval
Provider firms will be expected to have robust
procedures to assess their target market,
perform adequate stress testing, and manage
the product risks for consumers. We would
expect the sorts of standards that consumers
associate with basic vehicle safety or overthe-counter medicines, for example, to be
the norm for widely sold financial products.
Firms should also consider making their own
pre-approval processes more transparent; the
aim should be to increase the level of trust
consumers have in financial products.
Journey to the FCA, October 2012
3.1 New Product Development
The FCA have made it abundantly clear
that they intend to intervene earlier in a
product’s lifespan and seek to address root
causes of problems for consumers. The FSA
have already adopted this approach and have
subjected new product approval processes to
rigorous review in many firms.
The FCA say that they will do this in future by
scrutinising firms’ product governance and
how firms design, operate and sell products.
This may include assessing, for example,
whether the target consumers’ needs were
taken into account in the product design;
whether there is sufficient product oversight
and monitoring of practical outcomes for
consumers; and whether the distribution
strategies are appropriate.
In terms of Product Approval the FCA will
expect firms to demonstrate that they;
1. Identify the target audience and design a
product that meets their needs. So it has
to be very clear who the product is aimed
at, and for which customers it will not be
suitable.
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2. Test these products to make sure they can
deliver fair outcomes. This could involve
looking to see how the product would
fare under different scenarios, across the
product lifecycle, to basically see if it will
do exactly what the firm says it will do.
3. Have a robust approval process in place
before products go on sale. This will mean
that the sales process gets the product
in the right people’s hands. It doesn’t, for
example, allow very elderly customers
to invest in long-term or very high-risk
investments.
4. Monitor the product to see who is buying
it and how it is performing. This is not just
about selling it and moving on, but taking
an interest in how it is actually working in
practice.
All firms should therefore ensure that their
new product approval processes;
1. Have clearly defined roles and
responsibilities for those operating them;
2. Incorporate effective scrutiny and
challenge, including from functions
like legal, risk and compliance where
appropriate;
3. Embed the delivery of fair outcomes for
customers;
4. Include comprehensive reviews of sales
processes and any additional training
needs required for the new product;
5. Manage any conflicts between the firm
and the customer; and
6. Have clear criteria for when an abridged or
‘light’ process may be used and for what
constitutes a ‘new’ product.
3.2 Existing Products
Many firms have now developed a risk-based
Product Testing Programme, under which
all existing products are systematically
subjected to a regular review from a Conduct
Risk perspective.
Performance against the Product Testing
Programme will be audited and reported.
Risk-based criteria for assessing the priority
and frequency of existing product testing
will be determined by the firms’ Senior
Management and will include, but not be
limited to;
1. N
umber of customers holding the product;
2. Importance/criticality of product to
customer;
3. P otential for Conduct Risk or unfair
treatment in the product;
4. E xternal factors, including, but not limited
to, any regulatory focus (or fine) for the
same or similar products;
omplaint volumes in relation to the
5. C
product type (including any material
increase in volumes of complaints); and
The Product Testing process will include a
formal and documented review of;
1. P roduct features;
2. F inancial promotions;
3. T
arget market – and those for whom
product may not be suitable;
4. P roduct terms and conditions;
5. S ales processes and sales quality
performance;
6. S ales incentives;
laims performance (where applicable);
7. C
8. C
ustomer feed-back (where available);
9. B
arriers to changing the product;
10. Other products which could replace the
product and deliver better customer
outcomes;
11. Complaints history and trend data; and
12. Other relevant data
Conduct Risk and the FCA:What’s your next move?
3.3 Financial Promotions
One of our new powers enables us to ban
misleading financial promotions. This
power means we can remove promotions
immediately from the market, or prevent
them from being used in the first place,
without going through our enforcement
process. By removing the risk of harm we help
consumers; and other firms will benefit from
a more transparent process
Journey to the FCA, October 2012
The current FSA rules in relation to financial
promotions, as set out in the Conduct of
Business sections of the FSA Handbook,
are not expected to change to any great
extent under the new regime. There are
clearly sector specific requirements (for
banking, investment, insurance, mortgages
and other products) but in all cases there is
an overarching principle that promotional
material should be fair, clear and not
misleading.
Firms need to satisfy themselves that they
have robust systems and controls to comply
with the detailed financial promotions rules
relevant to the products and services they
are promoting. This should give the firm
confidence that;
All communications, through whatever
medium, and all financial promotions are
fair, clear and not misleading;
Financial promotions addressed to clients
are clearly identifiable as such;
Information is sufficient for, and presented
in a way that is likely to be understood by,
the average member of the group to whom
it is directed, or by whom it is likely to be
received;
l l Information for customers is accurate
and, in particular, does not emphasise any
potential benefits of products without also
giving a fair and prominent indication of
any relevant risks; and
Important items, statements or warnings
are not disguised or obscured.
l l Digital Media
It is very important for firms to consider
the impact of the financial promotions
rules in relation to their use of digital media.
This is becoming an increasingly powerful
tool for firms to promote their services to
clients and some commentators believe
there is something of a vacuum in terms of
regulatory requirements.
The FSA disagree!
We appreciate that digital media allows for
very effective ways to promote your business.
Unfortunately we continue to see examples
where the customer’s best interest is not at
the heart of digital promotions. For whatever
reason, too many firms seem to assume that
because the medium is different then the
rules must be different too. Let me say again
that this is not the case. Facebook and blogs
are not real time media and are not exempt
from requirements to describe risk and
disclose other key information.
18 Sep 2012 Speech by Clive Gordon Financial promotions: keeping connected and
compliant
Mr Gordon then provided some very useful
guidance on digital media as set out below.
Firstly, digital media may stay in circulation
longer than traditional media channels. For
example, a press advert is usually discarded
the same day, whereas a social media
advert has a longer shelf life. So you will
need to conduct regular reviews to ensure
that the information is up-to-date.
Secondly, consider whether the media
channel is a suitable method for the type of
product or service promoted. For example,
advertising a complex product on Twitter
would clearly not be fit for purpose.
Thirdly, make sure that risk information is
prominent and clearly displayed.
Fourthly, ensure the promotions and
communications meet our requirements
for stand-alone compliance. By standalone compliance, I mean our expectation
that every financial promotion must meet
all the relevant financial promotion rules,
regardless of where or how it appears.
And finally, if you can’t make the promotion
compliant within the allocated space, you
can’t advertise. For example, Twitter limits
the number of characters that can be
used, which may be insufficient to provide
balanced and sufficient information
l l l l l l It is very important for firms to consider the impact of the financial
promotions rules in relation to their use of digital media. This is becoming
an increasingly powerful tool for firms to promote their services to clients
and some commentators believe there is something of a vacuum in terms
of regulatory requirements.
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4. Sales – and Sales Incentives
Provider firms will be expected to have robust
procedures to assess their target market,
perform adequate stress testing, and manage
the product risks for consumers. We would
expect the sorts of standards that consumers
associate with basic vehicle safety or overthe-counter medicines, for example, to be
the norm for widely sold financial products.
Firms should also consider making their own
pre-approval processes more transparent; the
aim should be to increase the level of trust
consumers have in financial products.
Journey to the FCA – October 2012
Sales Processes
Most firms now have a programme in place
under which sales processes for all of their
products and services are subjected to a
regular review from a Conduct Risk and
Customer Treatment perspective.
Sales processes must be designed to
ensure that:
1. The needs of the customer are fully
understood and documented;
2. Each sale is suitable for the particular
customer; and that
3. Products are only sold to the correct and
appropriate target customers.
Sales processes will include detailed
provisions for records of the sale to be
maintained and readily recoverable in line
with statutory requirements. Robust record
retention and recovery processes are critical
in the context of future potential mis-selling.
In many of the large scale remediation cases
to date, the problems firms have faced have
been, at least in part, the result of not being
able to produce the evidence that the right
product was sold in the right way to the right
customer
Sales Incentives.
This bonus-based approach has played a
role in many scandals we have seen over the
years. Incentive schemes on PPI were rotten
to the core and made a bad problem worse.
Speech by Martin Wheatley – Managing
Director, FSA – 05 September 2012
Firms are expected by the FCA to have in
place effective controls to manage the
increased risk of mis-selling arising from
their incentive schemes. In addition effective
controls should be applied to manage the
risk from sales targets and performance
management. (Risks to customers from
incentive schemes may also arise in areas
such as complaints handling, claims
processing, mortgage arrears and customers
retention and these need to be considered).
Effective controls and governance will
include, as required:
obust risk-based business quality
1. R
monitoring and adequate controls
to mitigate the risk of inappropriate
behaviour during sales conversations;
2. M
anagement information to identify, and
act upon, trends or patterns in individual
sales staff activity that could indicate an
increased risk of mis-selling as a result of
features in the incentive scheme.
3. U
sing this management information to
inform the approach to monitoring sale
staff incentive risks;
4. P roper management of sales managers’
conflicts of interest;
5. E ffective oversight of incentive schemes by
appropriate Senior Management, including
approval of the incentive schemes; and
6. A
n effective risk identification and
mitigation process, including regular
reviews of incentive schemes and the
effectiveness of controls, taking into
account customers’ interests
Senior management in all firms are expected
to identify and assess the specific features
of their incentive schemes that might
increase the risk of mis-selling and ensure
controls are in place to adequately mitigate
the increased risks.
Senior management will approve incentive
schemes with input from risk management
and compliance functions into the design
and review of incentive policies – and in
doing this they will need to consider how
incentive scheme features can lead to poor
customer outcomes.
There should be frequent and effective
reviews of incentive schemes, at least
annually, with sufficient attention given
to risks to the fair treatment of customers.
Management information will be collected
and used by Senior Management to assess
if risks are crystallising and if controls are
effective in mitigating the risks.
Firms are expected by the FCA to have in place effective controls to
manage the increased risk of mis-selling arising from their incentive
schemes. In addition effective controls should be applied to manage
the risk from sales targets and performance management.
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Conduct Risk and the FCA:What’s your next move?
5. Post Sales Handling – delivering on
promises
5.1. Information
The provision of clear and easily understood
information throughout the lifecycle of the
product is crucial to ensuring consumers are
treated fairly. In particular, where consumers
do not take advice, they must rely on the
clarity of information when making decisions
on products and services. This is reflected
particularly in TCF Outcome 3.
Outcome 3: Consumers are
provided with clear information
and are kept appropriately
informed before, during and
after the point of sale.
As regards post-sales information, firms
will need to ensure that they have in place
systems and controls to ensure that;
1. Customers are provided with clear and
intelligible information, by the most
effective delivery channel, for the duration
of their relationship with the firm.
2. Technical terms are explained clearly using
commonly understood language.
3. The firm provides information at all times
in accordance with commitments made
so to do.
If customers seek information from the
business at any time and through any
appropriate means of communication, the
firm must deal with all such requests in a
timely and efficient manner
5.2 Claims
Where a firm offers products under which
consumers will be entitled to make claims,
particularly insurance products, the firm
must ensure that their claims processes
and procedures ensure the fair treatment of
customers throughout the claims process.
Claims performance must be closely
monitored through claims monitoring
and claims performance management
information which should include, where
appropriate;
1. Volume of successful claims and rejected
claims – including any trends over relevant
periods of time.
2. Speed of settlement and payment of the
claim.
3. Customer feedback from post-claim
surveys.
4. Complaints about claims – and root cause
analysis of those complaints.
5.3 Barriers to Switching
The FSA believe that good consumer
outcomes are more likely to be achieved
where customers can compare products
effectively and where customers do not face
unreasonable post-sale barriers to change
product or switch provider. The FCA will have
the same view.
Unreasonable barriers to switching might
include the following illustrative but nonexhaustive deterrent factors which firms
should look out for;
1. High/disproportionate penalties for
switching or closing accounts/products;
2. Excessive complication and administration
for the customer before they are able to
switch / close;
3. Unreasonable risk to the customer arising
from potential exposure during the
switching/closure process
4. Long initial exclusion periods (during which
a claim cannot be made) or extensive
exclusions
5.4 Complaints
Effective complaints management is
fundamental to Conduct Risk and Customer
Treatment and the FSA and FCA will continue
to monitor activity and performance in this
area very closely.
Senior Management will be expected to
demonstrate a culture which does not view
complaints negatively and which will:
1. M
ake it easier for customers to complain
and express their dissatisfaction;
2. Improve the investigation and prompt and
appropriate decision making of complaints;
3. C
ommunicate clearly with complainants;
4. G
enerate meaningful and granular
management information and use this to
guide decisions; and
5. Identify and tackle the root causes of
complaints to prevent similar problems
re-occurring.
Firms will already have appointed an
individual, to have responsibility for oversight
of compliance with the FSA’s complaint
handling rules in the FSA Handbook in relation
to disputes (“DISP”). The individual appointed
must hold a governing function at the firm (or
in the overall Group).
The ‘Complaints Officer’s’ typical
responsibilities will be to;
1. P rovide oversight of the firm’s compliance
with DISP;
2. A
ct as a single point of contact for the FSA
for complaints handling;
3. E nsure that the firm complies with
requirements to publish complaints data,
either by business unit or in aggregated
format, within time limits and in the format
required by the FSA (where required);
4. E nsure that sufficient resources are
allocated to the complaints-handling
function;
5. E xert pressure on other parts of the
business to take appropriate action
where failures elsewhere are leading to
complaints;
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6. Reviewing management information (MI)
in relation to complaints and assessing
whether it is fit for purpose. Specifically, the
MI should be robust and detailed enough
to allow meaningful root cause analysis
to be carried out, in accordance with the
requirements of the FSA rules, and to
enable the firm to be sure that it is treating
its customers fairly;
7. Reviewing MI and assessing whether
appropriate actions are taken in response to
the results of root cause analysis; and
8. Ensuring that sufficiently senior individuals
lead complaints activities across the firm.
Firms should take into account the nature,
scale and complexity of its business
(including, in particular, the number of
complaints the business unit receives) and will
put in place appropriate processes, systems
and controls in order to comply with the FSA’s
requirements.
Root Cause Analysis
Root cause analysis remains a key focus of
the FSA so every firm should ensure that
they have in place robust and proportionate
systems and controls to ensure;
1. The collection of management information
on the causes of complaints and the
products and services complaints relate to,
2. A process for analysing the causes of
individual complaints so as to identify root
causes common to types of complaint
3. A process to prioritise dealing with the root
causes of complaints;
4. A process to consider whether the root
causes identified may affect other
processes or products
5. A process for deciding whether root causes
discovered should be corrected and how
this should be done;
6. Regular reporting to the Senior
Management where information on
recurring or systemic problems may be
needed for them to play their part in
identifying, measuring, managing and
controlling risks of regulatory concern; and
7. Maintenance of records of analysis and
decisions taken by senior personnel in
response to management information on
the root causes of complaints.
Final thoughts and conclusions
There is no ‘right way’ to manage
Conduct Risk effectively.
Senior Management, from the CEO
down, must be fully engaged in the
approach to Conduct Risk employed
by the firm.
Each firm must consider and articulate
very clearly what Conduct Risk means
to them.
Every firm should be able to
demonstrate that they have identified
potential Conduct Risks and put in
place appropriate and proportionate
controls and management
information to mitigate the risks
identified.
Firms must ensure that they have
devoted sufficient resources to the
effective management of Conduct
Risk.
The focus on conduct issues by the
FCA will be relentless.
The expectations of the FCA will
continue to evolve.
TCF has not gone away – and firms
need to ensure that their approach
to conduct risk builds on, and
incorporates their approach to TCF.
Conduct Risk is all about delivering
the right outcomes for consumers –
and fixing things when this does not
happen.
Effective management of conduct
risk will deliver better results for
customers – and could even be used to
enhance the reputation of the firm.
l l l l l l l l l l Essentially, we will be looking for firms to base their business model, their culture,
and how they run the business, on a foundation of fair treatment of customers as
set out in the Treating Customers Fairly (TCF) initiative. While we recognise that
firms need to be sustainable, we will not let a firm compromise fair treatment of
customers to achieve financial success.
Journey to the FCA
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Conduct Risk and the FCA:What’s your next move?
The Group’s Conduct Strategy and supporting framework have been
designed to support its vision and strategic aim to put the customer
at the heart of everything it does.The Group has developed and
implemented a framework to enable it to deliver the right outcomes
for its customers, which is supported by policies and standards in
key areas, including product governance, customer treatment, sales,
responsible lending, customers in financial difficulties, claims and
complaints handling.
The Group actively engages with regulatory bodies and other
stakeholders in developing its understanding of current customer
treatment concerns.The Group develops colleagues’ awareness
of these and other expected standards of conduct through these
and other policies and standards and codes of responsibility. It also
undertakes root cause analysis of complaints and makes use of
technology and metrics to facilitate earlier detection and mitigations
of conduct issues.
Extract from LBG 2012 Results – PRINCIPAL RISKS AND UNCERTAINTIES
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risk, or working toward a holistic risk management strategy, more than
15,000 customers worldwide count on Wolters Kluwer Financial Services for
a comprehensive and dynamic view of risk management and compliance.
Wolters Kluwer Financial Services provides audit, risk, finance and
compliance solutions that help financial organizations improve efficiency
and effectiveness across their enterprise. With more than 30 offices in 20
countries, the company’s prominent brands include: FRSGlobal, FinArch, ARC
Logics for Financial Services, Bankers Systems,VMP® Mortgage Solutions,
AppOne®, GainsKeeper®, Capital Changes, NILS, AuthenticWeb™ and
Uniform Forms™. Wolters Kluwer Financial Services is part of Wolters Kluwer,
a leading global information services and solutions provider with annual
revenues of (2012) €3.6 billion ($4.6 billion) and approximately 19,000
employees worldwide.
Please visit our website for more information.
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