Remediation Programmes
Acknowledging the reality of remediations

Recently, Matt Beattie – Managing Director at Beyond – hosted a webinar with Nick Ford – VP Strategic Alliances at Encompass (a Regtech focused on KYC automation) – on the subject of “Achieving lasting success through effective remediation programmes​”.  

Why is remediations a hot topic? Well, in reality very few people or organisations want to talk about remediation or acknowledge that these are a reality of their business. Most consider these to be one-off exercises that just need to ‘get done’. Naturally, people want to be talking about their strategic programmes.​ 

However this ignores the reality that, for most organisations, remediations have become a regular occurrence. They are often the thing that stops people from getting to their more ‘strategic’ initiatives in the first place. Remediations can absorb much of the time, money and energy that is available for ‘change’, meaning that change is put on the backburner.  

A reality for Financial Institutions
We need to talk about remediations

Part of the problem is that we don’t talk about remediation. In particular, we don’t talk about how we can make these successful – not just in delivering their required outcome, such as remediating a client population – but in helping to deliver our strategic goals.  

So how can you overcome some of the common challenges and turn your remediation into a programme that can deliver lasting value? Here are the key take-aways: 

1. Reframe the remediation​ 

Rather than simply view the remediation as an issue that needs to be resolved, reframe the remediation as an opportunity to develop the environment, to build what should have been done in the first place.​ If this can be done, remedial work can be viewed in an entirely different light​.  

When approaching any remediation, leaders should be asking themselves: “how can we ensure that we don’t have to do this again?”. Remediation can be the driver to look at a more strategic, long term solution to ensure that you’re not only solving the problem for now, but for later also.  

It starts to change the mindset from ‘get this done’ to ‘build for the future’​. 

2. Know your why​. 

For anyone leading a remediation, it is critical to understand why you are doing the remediation. This may sound obvious, but it is critical that you understand not just what you have been asked to do, but ultimately what needs to be achieved.

If you’re owning/running the remediation, you need to be sure it will achieve the end objective – there are no prizes for delivering on a scope that didn’t solve the challenge​.

It’s important to be careful though. Use that purpose to also control the scope of the exercise. When attempting to use the remediation as a vehicle for more strategic purposes, it can be easy to be caught up in the ‘wouldn’t it be great if…’ discussions but this can distract from the task in hand​ and needs to be controlled closely.

3. Under promise, over deliver 

This is a tenant of any good programme delivery but is especially important for remediations where there is ‘top-of-the-house’ as well as regulator scrutiny.  

Your communication of delivery and timelines should always err on the conservative side as no one will reward you for delivering more (or quicker) than was expected. However, there will be significant issues to deal with should you not meet your commitments.  

We would also advise that you don’t commit to anything that hasn’t been requested by the regulator. Once you have committed to doing something, the regulator will want to see that this is carried out to their required standard.   

4. Measure twice, cut once 

The task of managing the client population is often one of the most significant challenges of any remediation. It is critical to get a handle early on in the process on this population.  

To do this, it is critical to truly understand why you’re doing the remediation (see above) and then define how that translates to the client population. By interrogating the initial client population and asking a number of drill-down questions, it is often possible to further reduce your population through de-scoping.  

Taking a “measure twice, cut once” approach, we would encourage you to spend the time upfront to understand your client population and approach. This will allow you to have a (more) stable population through the remediation exercise and provide a more solid foundation for estimating timeframes and delivery dates. 

5. Embed data maintenance into BAU 

 As stated above, any remediation programme should be looking to not only solve the immediate issue, but ensure that the issue is being solved in the long-term by creating a sustainable process.  

This means that the key parts of the remediation (data / documents / process / controls) need to be embedded into BAU processes.  

This is where tooling can be of huge benefit. Leveraging existing or new tools to support the efficient execution of the remediation process, but also embedding these tools into BAU (to potentially support a broader set of processes) can be a way to ensure that the cost of remediation delivers some long-term value back to the business.  

 

Listen to the webinar “Achieving lasting success through effective remediation programmes​” on-demand here for more practical advice and examples.  

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