Conduct Risk

The Individual Accountability Framework - Key Decisions before Implementing IAF

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This article is a continuation of a series from Grant Thornton Financial Services Advisory that focuses on key aspects of Individual Accountability Framework (“IAF”).

In this article, a focus is given to key decisions that RFSPs will need to consider making before implementing IAF. These decisions will shape your programme and touch on areas including implementation, organisational culture, technology solutions and existing controls. 

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With regard implementation, you will need to decide who owns the programme and when it will commence. Should your organisation start implementation of IAF before the Central Bank of Ireland Bill is enacted and the guidance published? The implementation of IAF in your organisation may involve a significant programme of cross-departmental projects. As such, it is important to decide what success looks like when it comes to IAF: will compliance be enough? On the other hand, will your organisation only consider its IAF programme a success when the spirit of accountability is evident across your senior management?

The Regulator has seen the organisational culture of Irish Financial Institutions as an area of weakness for more than 10 years. IAF is a means of addressing this issue, by strengthening individual accountability. Your organisation should decide whether a cultural audit and periodic cultural reviews would be necessary after implementation, to assess if IAF is embedded in the organisation and is having the desired impact on culture.

With regard technology solutions, your organisation will need to decide if it invests in a solution for the implementation of IAF and if so, which solution provider to partner with. It is also important to be aware that reg-tech solution providers can have long lead times, so leaving this decision until the final hour will delay implementation and reduce the number of potential providers available.

Finally, your organisation will need to assess its existing controls relating to Fitness & Probity, Code of Conduct and Senior Executive job specifications. It is likely that at least one of these areas will need adjustment ahead of IAF. The decision here centres on whether your policies and controls in these areas need a radical overhaul, or a number of minor adjustments.

In summary, all RFSPs should be aware of what we know so far about IAF given how imminent its introduction is. Several key decisions can be made to facilitate a smooth journey to compliance. By making these decisions ahead of time, and not under the burden of a regulatory compliance clock ticking, firms can set themselves up for a well-planned and executed implementation.

Our Services and Contacts

Grant Thornton Ireland are well positioned to help your organisation deal with its IAF and SEAR-related queries. From bespoke advice to large-scale implementation projects, our subject matter experts in Conduct Risk are here to help your organisation with all things IAF-related.