Engagement Summary
In early 2021, Monticello Consulting Group (Monticello) partnered with the Change Management team at a leading financial institution to support the delivery of a large-scale market conduct risk remediation program to comply with Consent Order directives from the Federal Reserve Bank of New York (FRBNY). This program was initiated by the client in response to a regulatory examination, which found the bank lacked sufficient internal controls to mitigate misconduct across designated market activities of in-scope businesses. The goal of the program was to transform and enhance the following frameworks and capabilities:
Conduct Risk Framework
First Line of Defense Controls Testing Capability
Transaction Monitoring Capability
Trade Surveillance Capability
Supervisory Framework
Accountability Framework
Order and Execution Data Management Solution
Monticello deployed resources across numerous program workstreams to support the delivery of control solutions, as well as the Program Management Office (PMO) to track project plans, key milestones, risks, issues, and dependencies. The Monticello team combined their proven program governance toolkit and effective stakeholder communication to ensure key program risks and issues were successfully mitigated and resolved through sound governance. Given the public nature of Consent Orders, there is heavy scrutiny and oversight from senior management up to the Board and C-suite executives. By implementing a dedicated Program Management Office to centrally manage the governance structure across program workstreams, Monticello was in a position to effectively hold stakeholders accountable, execute a clear communication strategy and maintain project momentum towards meeting major milestones in a timely manner.
Additionally, Monticello managed all program reporting obligations and supported senior leadership and program sponsors through bi-weekly program status updates to the program’s working groups and Steering Committee. The team also produced comprehensive reports for the bank’s compliance executives and the FRBNY on a monthly and quarterly basis, respectively, to present progress made against the firm’s regulatory commitments.
Case Study Detail
PROJECT BACKGROUND
The FRBNY assessed a substantial civil penalty to Monticello’s client, a leading financial institution. Regulators concluded that the bank lacked sufficient firm-wide governance, risk management, compliance, and audit policies and procedures to effectively mitigate misconduct across banking practices.
ENGAGEMENT OBJECTIVES
Program Management & Governance
Managed program governance under the change management function for the Global Markets business. Monticello supported the Program Management Office to drive the timely delivery of Consent Order mandates through stringent execution of project plans, timely risk and issue management, and robust governance standards. The PMO function included the following responsibilities:
Define reporting routines and effective program governance processes to satisfy requirements and align with business needs.
Chair program-wide meetings to liaise with workstream PMOs on project statuses
Identify and manage program key issues, risks, and internal/external critical dependencies.
Ensure adherence to enterprise-wide program management standards.
Maintain end-to-end book of project attributes in central tracking and risk management tool for stakeholder visibility
Stakeholder Communication & Reporting
Leveraged a strategic communication structure to provide tailored updates to stakeholders at varying levels of seniority and accountability for program deliverables. Critical program information was communicated through a dashboard that highlighted program status, the path to green plans, and key risks, issues, and dependencies. In addition, the PMO tracked key performance indicators (KPIs) to measure workstream progress against books of work. The team also raised all off-track and at-risk milestones for review and guidance from senior program executives.
BUSINESS VALUE
Monticello Consulting Group provides services across the financial services industry to establish compliance and reduce regulatory risks. By leveraging our program governance toolkit and strong stakeholder communication, Monticello enables clients to successfully navigate complex regulatory directives and turn challenges into opportunities to build effective business solutions. Our team partners with cross-organizational client teams and oversees the end-to-end execution for Consent Order remediation. With deep regulatory knowledge, change management expertise, and proven governance standards, Monticello successfully ensures global financial institutions can maintain a competitive advantage over industry peers while exhibiting sound market conduct and compliance within the regulatory landscape.
