Here are some of the common issues that are slowing down the review process.
Delayed visits
Our Quality Assurance Department’s insolvency team carry out around 150 reviews a year and have visits scheduled every week. It’s therefore unlikely we will have a short-term gap available to conclude a delayed visit. Delays impact both you and the reviewer. Please try and ensure delays are kept to a minimum to help us conclude your review as quickly as possible.
Ensure availability of key staff and IPs
Please ensure that key staff will be available during the visit. We appreciate that you also have to do the day job, but making sure the case manager is on site during the visit will mean you can give us prompt responses to our queries.
All IPs covered by the visit need to be available. We have had visits where, despite dates being agreed ahead of time with the compliance team, we have been notified just before the visit that one of the IPs is going to be away (eg, on holiday). As they (rightly) want to contribute to the responses on their cases, that causes an avoidable delay. While we understand that casework and new jobs can impact on availability, we don’t expect IPs to take holiday during agreed visit dates.
Plan for and manage compliance input
Some IPs want to run their responses by their compliance provider (if they have one) before sharing them with us. If you choose to do that, please:
- ensure the compliance provider is lined up to do that and will be able to look at the responses as they come through without an undue delay; and
- remember that our query responses are just the first stage in the process. You will get a further opportunity (usually 15 business days) to provide a written response to any matters that go into the closing record. That may be where you need compliance input into any changes that need to be made to address our findings.
Ensure electronic data is properly accessible
Where records are kept digitally, these need to be made available to us in a way that we can easily access the content, and they can be searched. All documents must be able to be downloaded. It slows us down considerably if we can’t search for documents, if all documents have the same download date or if documents aren’t appropriately named. Long file names can prevent us being able to extract files from file sharing platforms.
Delays in query responses
One of the most common problems we encounter is getting prompt written responses to our queries. This is a key part of the quality assurance monitoring process and is essential to ensuring we can conclude the visit in the time allowed. Once we have your written responses (and any additional papers), we need to review them and conclude on the individual issues and draft a closing record.
Note that extensions for IPs to respond to our closing record are only available in exceptional circumstances and IPs need to ensure they keep to the timeframe provided where it is in their control to do so.
By helping us to make the visit process as smooth as possible, visits are run more efficiently and can be concluded within the agreed timeframe.
