By John Clements, Director, TPI, EMEA
Although many of the considerations that apply to Financial Services Operations (FSO) outsourcing apply to any type of outsourcing, certain considerations are amplified because of the regulated environment in which financial services institutions (FSIs) operate.
Here are the TPI Top 5 considerations to take into account when outsourcing an FSO process.
1. Institute, maintain and demonstrate control
In most jurisdictions, FSIs will not be able to outsource their regulatory responsibilities when undertaking a material outsourcing project. Regulators are likely to require early communication about a potential outsource and will want to know how the FSI is going to maintain control in the outsourced environment. Therefore, it is important that structures and processes are put in place pre-contract to maintain control (e.g., your governance team, management information and reporting, compliance and audit plans, risk management, etc.).
No organization can predict the entirety of regulatory change that may be coming down the road in an outsourcing relationship. Therefore, in an outsourcing agreement, a certain amount of regulatory change can be bought from a service provider via a contractual concept called “regulatory buyout.” This means that the service provider assumes the risk of making regulatory changes to its outsourced environment.
3. Factor in the end-user experience
It is probable that the outsourcing of an FSO process will result in end-user contact (e.g., the people who buy or advise on financial products) being outsourced to a service provider. Therefore, it is vital that the end-user experience is a critical part of the contractual service level agreement regime, and effective process handoffs should be planned into transition so as not to impact the end-user experience.
4. Actively manage operational risk
Operational risk can be introduced into an outsourced arrangement via a multitude of channels such as staff attrition leading to loss of key skills, data protection risks (particularly as customer data may be processed by a third party), cutover of operations to the service provider, unsuccessful system re-platform leading to the loss of customer data, and more. Therefore, an FSI must manage operational risk by instituting and enforcing an effective risk management framework that encompasses the outsourced environment.
5. Know how you will exit the arrangement
Understanding your exit strategy is a crucial part of any FSO outsourcing project — even before service transition has begun. This involves more than just ensuring that the service provider has contractual obligations to produce an exit plan. What are the trigger events for bringing a service back in-house? How would you bring the service back in? What team would you set up, and with what skills? How long would it take? How are you maintaining the knowledge that you have outsourced?
TPI’s seasoned FSO experts can help you achieve your sourcing and goals through objective advice, knowledge of your industry and experience with arrangements from simple to complex. E-mail John Clements, Director, TPI, EMEA, or phone him at +44(0) 7879 424 075 to learn more.