Unless it happens to be a fundamental part of your job, very few people get excited by management information (or MI as it’s usually referred to. In fact, who calls it by its full name anymore?)
After all, it’s just there to provide figures, data, trends; whatever you need to use it for.
But maybe it’s time to look at MI in a different light – maybe it’s time to think about what MI can tell us about our training needs, not just information about the business.
The regulators are interested too
There’s no doubt that regulators are very interested in the MI that firms produce. Think about all of the MI that needs to be submitted on a regular basis (such as product sales data, persistency data, funds under management etc). Then think about everything that they ask for during supervisory visits or desk-based reviews.
The key point here is that not only does the MI have to be accurate and up to date. It needs people who are well-trained, are able to understand what the data means and how it is best presented.
And that means making sure that people who compile MI (from whichever department) have the necessary skills and knowledge to be able to deliver the quality of MI required.
So, whether the training needs include, for example, an understanding of regulatory requirements, or for a knowledge of how to compile scorecards, ask yourselves “Has this been adequately addressed? “
One for the advisers
For the financial adviser community (and for those who operate in control functions relating to advisory activities) MI is absolutely crucial. So much so that the FCA has a page on its website of resources designed to help firms compile this.
The key concern for the FCA here is that the quality of advice given by firms and their representatives is carefully monitored. One of the cornerstones of good advice is the training and competency scheme (T&C), and in particular, the MI that sits behind it. It’s the MI that can help establish how well certain advisers are doing with the progress towards competency. The MI can also track how well ongoing learning and development is going for experienced advisers. It can also tell you how much management support is being provided to advisers.
But again, the MI lives or dies by the ability of the people producing it, and by the people interpreting it. They need to be able to put across and receive the message that it is trying to give. And that in itself comes down to training – in this particular case, accompanied by an understanding of T&C schemes and the results they are supposed to produce. Quite often, training programmes designed to educate people in T&C schemes include an element on how to produce and interpret MI.
Then there’s financial crime
This is good timing, because last week, the FCA issued its update to “Financial Crime: A Guide for Firms.”
One of the points addressed by this document is MI. Here, the FCA has made it clear that it expects senior management to make sure the MI they receive gives them the right amount of information to understand the financial crime risks that are relevant to their firm; and then subsequently implement the right controls.
The FCA cite many examples in the updated Guide, but broadly, the MI should be telling senior management (and in particular, the MLRO), firstly what the risk assessment looks like; where the key risks lie both now and in the future.
Secondly, what sort of activity is going on in the firm on a day to day basis. So, how many sanctions matches are made, and how many screening tests are carried out? Also, how many PEP relationships does the firm have, and how many cases required enhanced due diligence? Last but by no means least, how many suspicious activity reports were made to the National Crime Agency?
All of this is really important stuff – but it won’t come to life until someone puts it together – and then someone on the other end has to have the right understanding to be able to interpret the MI and use it to ensure the integrity of the financial crime controls.
All of this takes skills and knowledge – as a result, many courses on financial crime cover this subject.
And then there’s the actuarial stuff
It wouldn’t be right to talk about MI without mentioning Solvency II. After all, it’s a rather big development for insurers, which is now not too far away.
The amount of MI that will be needed to be produced to both understand the capital figures that are required under Solvency II, and then be reported to the regulators, will be substantial.
And again, it’s not just the production of the MI – it’s the understanding of what this data means that’s important too. For those people who are entrusted with the task of producing the data that sits behind the submissions, they have to make sure they understand what is involved in getting this right. And those who have to answer to regulators really need to understand what the figures are telling them.
The good news though, is that there is still time, and there are a number of Solvency II courses available to help with outstanding training needs.
So there you have it. MI isn’t just a set of figures on a page. It’s the lifeblood of any firm, and a key link to a good regulatory relationship. So the training needs for those who deal with and interpret MI really shouldn’t be neglected.
And the best place to start is with Industry Events Online search page. With yet more training providers joining, this is more true now than it’s ever been.
By Martyn Oughton a Professional Member of the International Compliance Association (ICA). Martyn now writes a regular blog for Industry Events Online focusing on the importance of training in all aspects of compliance. Read Martyn's other publications at Martyn's Writers' Residence website.
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