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11th December 2015
Regulatory fine for Risk Management failures
The FCA has today fined Ms Paivi Grigg £14,807 for regulatory breaches whilst holding the position of Risk Management Director at Financial Limited and Investments Limited.
In the FCA’s Final Notice, the regulator explained clearly the areas that came under of Ms Grigg’s responsibility and where she failed to measure up and perform these duties. Regulated firms can take lesson from Ms Grigg’s regulatory fine and review and assess if their own Risk Management processes and procedures are up to scratch in light of the comments by the FCA.
The Financial Conduct Authority considers risk to be a combination of impact and probability i.e. the potential harm that could be caused from something happening and the likelihood of that particular issue or event occurring.
When assessing risks, weighing up the combination of both impact and probability factors will provide firms with a gauge of the overall risk posed to them and their businesses. From this, firms should be able to then prioritise their risks from which they can then address and make any decisions on courses of action and resource allocation as necessary.
The regulator identified that in Ms Grigg’s role as Risk Management Director, her principal risk management responsibilities were:
Following the regulator's investigation, it emerged that Ms Grigg not only breached her responsibilities as an Approved Person in failing to carry out her duties with due skill, care and diligence, but she also failed to understand her Risk Management responsibilities and failed to adequately identify, manage and control the material risks arising from the firms’ business model.
As a result, together these failures resulted in an inadequate risk management framework to mitigate risks particular to the nature, scale and complexity of the firm and its business.
Ms Grigg’s failures resulted in a £14,807 fine and should act as a wake up call to those managers within firms that are responsible for managing risk. Firms, particularly those affected by the implementation of the Senior Managers Regime (SMR) next year, should ensure that they:
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Risk Management: Key Responsibilities
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Risk management is designed to:
Impact of the problem if it should occur
Probability of the problem occurring
Scale of the potential risk