A major UK life provider working exclusively in the High Net Worth marketplace faced considerable remedial action regarding possible churning following a visit from FSA. We were appointed to assist under a Section 166 and in collaboration with the client we agreed a project plan and methodology for tackling the remedial work, which was successfully presented to the FSA. We established one team to check all new business and another to review a sample of past business. This required us to build case handling processes and a database to record MI.
Our approach was to help limit the work undertaken to that which was necessary and reasonable. We established a highly experienced and qualified team that checked an average of 120 complex new business cases per week and reviewed over 600 past business files.
Having prepared carefully verified MI for the FSA, we were able to identify the issues for the client but avoid an imposed full scope business review, as we demonstrated that investors had not been disadvantaged in the majority of cases.
We also assisted the client in identifying record keeping issues and new business processing shortcomings.
The collaborative approach adopted enabled the client and the FSA to be kept fully aware of the progress at all times, but also to have valuable input into the process and methodology as the project evolved. Additionally, the client benefited from our ability to provide expert resource, deal with fluctuations in workload and assist with all interaction with FSA.
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