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Our client, South West Credit, worked with us to develop a wholistic training project covering multiple aspects of the new Design and Distribution Obligations regime and the differing interests of multiple areas within their business
South West Credit Union Co-operative Limited (South West Credit) was one of the first businesses to make informal contact with GRC Solutions seeking an understanding of what support we would be able to develop and provide to help them comply with their obligations under the new Design and Distribution obligations laws. Discussion with industry participants revealed that the scope of the necessary support was large – our clients needed: support to understand the nature of the changes and to build the knowledge and talent necessary to develop internal processes; check-ins to ensure businesses were on the right track; and training at multiple levels in their business.
The new product Design and Distribution Obligations (DDOs) represent a very significant regulatory and cultural change for financial services businesses in Australia. The purpose of the obligations is to ensure consumers obtain appropriate financial products by requiring issuers and distributors to have a consumer-centric approach to the design and distribution of products.
South West Credit Union Co-operative Limited (South West Credit) was one of the first businesses to make informal contact with GRC Solutions seeking an understanding of what support we would be able to develop and provide to help them comply with their obligations under the new laws. Discussion with industry participants revealed that the scope of the necessary support was large – our clients needed: support to understand the nature of the changes and to build the knowledge and talent necessary to develop internal processes; check-ins to ensure businesses were on the right track; and training at multiple levels in their business.
It became clear that clients would require a wholistic training project covering multiple aspects of the regime and the differing interests of multiple areas within their businesses.
GRC Solutions opted for a staged roll-out of support for these changes, with the initial focus on training and preparation of management-level staff. The rollout schedule consisted of the following:
A total of eight micro-learning bulletins were scheduled for a staggered distribution campaign throughout 2020-21, progressively updating clients on developments in the implementation of the regime and covering items such as the opening of industry consultation periods, the development of regulatory guides by ASIC, a Q&A to raise awareness of general staff, together with publication announcements for relevant GRC Solutions’ resources that would further equip and empower clients to uplift processes in anticipation of the new obligations.
The regulatory instrument covering regulatory requirements for the implementation of the DDOs within financial services business was issued just before the Christmas-New Year break for 2020-21. In January 2021 GRC Solutions’ specialist team of financial services compliance lawyers commenced research and development of GRC Solutions’ support materials, with rollout occurring in April 2021. 24 individual businesses have subscribed.
The online training seminar on the DDOs, directed mainly at Compliance Staff and Managers, was held on 9 March 2021 and attracted 90 individual attendees from the industry. Senior staff members from most businesses in the sector attended. Slides and a recording of the seminar were made available.
The learning course was published on 10 June 2021 and was rapidly subscribed to by 17 clients. The training contains an overview of the DDO regime, the relevant regulator, the procedural requirements and the risks posed to businesses that fail to comply, but it is most heavily weighted towards actual scenarios: how the regime will apply to the five most common products handled by customer-facing staff and how staff will be required to act in order to comply.
At the time of writing, 2,154 staff across the industry have been enrolled by their businesses in the training. The majority of these have successfully completed the training.
The August 2021 edition of The Decisive Board, GRC Solutions’ e-magazine training product for Board members and senior management, contained an overview of current legislative activity and included detail on the DDOs.
The webinar, held on 22 September 2021, attracted 125 industry representatives. It was presented by two industry experts and focussed on issues that were likely to arise post-implementation, in particular: the ongoing management of arrangements between issuers (eg banks) and distributers (eg brokers) within the regime; the management of the cultural change issues that are likely to become most acute once the regime is in place; and issues and concerns relating to the ongoing monitoring and reporting obligations.
One of the most significant project outcomes is the demonstration of GRC Solutions’ capacity to mobilise its resources to create a wholistic response to an industry challenge, and to do so within a constricted timeframe.
The project has delivered the support and training required to assist mutual banking sector businesses to be ready to comply on and from the go-live date of 5 October 2021. The importance of this cannot be underestimated as the regulator has made it clear that compliance with the regime will be required from the outset. This contrasts with a more tolerant approach being adopted with respect to compliance with some of the other regulatory changes coming into effect in October 2021. The DDOs are intended to address an important consumer protection issue and, as such, are non-negotiable. Businesses that have adopted the GRC Solutions' solution are in excellent shape to satisfy the regulator of their compliance. In particular, customer-facing staff and their direct managers are now fully cognisant of their responsibilities and as a consequence of that, businesses’ risks of regulatory intervention are mitigated.
Feedback from clients across the industry was very positive, and the solution has been participated in by most members of the sector.
Kylie Brookes, Risk & Compliance Manager at South West Credit had this to say:
The training manual for Design and Distribution assisted me with understanding what was required of us going forward with this regime. I was then able to plan out all the requirements and exactly how to train our staff so they fully understood what was expected of them. Our staff then completed the training component which sits in Salt [GRC Solutions’ Compliance LMS]
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