In response to a Deferred Prosecution Agreement (DPA), our client needed to implement a set of standard policies in alignment with global policy standards.
The new policy was overly onerous for funds and out of alignment with market expectations. Rollout of this policy would have caused a spike in the cost of compliance (against a backdrop of cost reduction) and resulted in the loss of customers and revenue.
The client required their funds policy to be reviewed and simplified to ensure that they were in line with the market, and that the policy could be adopted in all 56 regions.
The policies for funds required a rapid and extensive redesign to prevent the loss of customers, and the requirement for considerable additional FTE overhead to apply the proposed standard.