Our Value
Banks have been very successful in their responses to regulatory mandates establishing adequate levels of controls. However, approaches to risk and controls management remain inconsistent. Maturing this area will be of great benefit to the reputation and standing of banks.
GreySpark leverages expertise across electronic trading, regulatory change and trade surveillance to deliver strategic solutions tailored to meet your business requirements. We implement a vertically-integrated approach to risk management processes and controls and embed it into the fabric of the organisation, thereby delivering new cultural awareness across the entire bank.
We recognise that each problem is unique and that it is not possible or healthy to apply a one-size-fits-all technological solution. The GreySpark mission is to best utilise our expertise and cross-disciplinary teams to thoroughly understand our client needs, provide industry-leading, actionable advice and deliver innovative, bespoke solutions.
Risk Management Service Offering
Comprehensive Model Risk Management Services
Delivery
It is clear that in the second half of 2018 the regulators and regional authorities, such as the FCA, will start to focus on firms’ compliance with MiFID II.
Regulators will inspect market participants to ensure compliance with the regulation.
GreySpark’s expectation is that institutions will see many of their non-compliant procedures exposed.
At the very least firms will need to be able to evidence activity working towards compliance.
Initial feedback to GreySpark indicates that the focus of the regulators will be on compliance within these key areas:
Simply altering existing policies and producing new documents, mapped to the regulatory requirements, is not enough. Regulators are looking for sustainability and enforcement throughout the organisation.
Documentation must not only meet all regulatory requirements, but also be developed in line with industry best practices, be consumable by an external regulator and be consistently deployed and implemented across the business.
A lack of top-to-bottom coordination and unclear oversight will lead to increased scrutiny from the regulator.
Establishing a governance framework and structured independent functions, providing oversight, allows for the identification of risk.
Adequate identification of risk allows for necessary adjustment to:
The dynamic regulatory landscape requires an operational shift in the industry’s approach to new legislation.
A ‘digital’ framework for regulatory management introduces the ability to improve the adaptability of an organisation.
By implementing the aforementioned framework, regulatory change can be realised in an iterative manner that best utilises the existing resources.
Establishing a ‘digital’ framework through GreySpark’s ability to:
There is a consistent trend of global regulatory upheaval, with advantages to be gained by firms that can best react to this dynamic situation.
Initial feedback to GreySpark indicates the current key regulatory challenges that firms are working towards are:
Financial services firms are now being monitored up by EU regulators to review their annual self-assessment of algorithms against the MiFID II RTS 6 requirements.
Given the increased level of regulatory attention, it is important that those firms begin to consider the best approach for the self-assessment and effective operation of algorithmic trading environments.
Establishing a comprehensive and well-documented self-assessment report, measured against industry best practices and address any gaps identified.
Although the model misk management (MRM) lifecycle concept, introduced by the FED’s SR 11-7, is widely understood and accepted across the industry, GreySpark Partners has identified common challenges amongst banks of different tiers with regards to its practical implementation. These include but are not limited to:
GreySpark has worked with a number of banks to assess the maturity of their current approach to MRM practices. As a result, GreySpark has built an established view on what constitutes industry best practice and can help bring the right advice and expertise to bear as banks look to continually improve and optimise in this space. GreySpark can help in the following ways:
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