What they needed
When the Regulator, as a result of thematic review activity, highlighted serious risks for investors in Unregulated Collective Investment Scheme (UCIS) funds we were called upon to assist with a series of investigations to establish the extent of exposure, and risk, within businesses that made up the wealth management division of our client, a major composite financial services institution.
How we helped
Momenta deployed a project manager, an SME and a small review team in order to implement a ‘pilot’ sampling review across the business portfolio which included:
assessing the guidance given by advisers
determining whether further action was appropriate
advising on what form any action should take
The pilot exercise established that across several firms, there was a systemic advice issue that needed to be addressed, and Momenta were appointed to set up and deliver a full review project.
A big challenge in designing the appropriate review and remediation scheme was that, at the time, there had been no precedent set for the review of UCIS sales and advice in the industry – a challenge that the Momenta team embraced, took forward, and solved by:
Designing a review process and a set of standards that were subsequently presented to and approved by the regulator
Adopting a pragmatic approach to case selection and review scope
Creating a redress calibration and calculation model fit for Regulator sign-off
The outcome
Once the above had been agreed Momenta created a project delivery plan, and sourced an appropriately skilled team of reviewers; which included a customer communications lead, review team leaders and a quality control function. Alongside the review resources Momenta also put in place a redress calculation function. a management information pack and a reporting dashboard.
As part of the programme governance, a professional services firm was engaged to provide external validation of both project progress and case outcomes. The momenta team maintained a quality standard on case outcomes above 98% throughout the review. In addition the project was completed on time and within allocated project budgets