Mission: control in financial services
The emergence of the Chief Controls Officer
The control of non-financial risk is a key priority for the first line of defence, and for the Chief Operating Officers charged with accountability for managing risk. Attention from boards of directors, regulators and auditors has sharpened focus on the topic, while COOs grapple with the associated challenges of compliance with the Senior Managers Regime, complex legacy environments, cost pressures, fragmented assurance approaches and a rapidly evolving threat landscape.
An increasing number of large financial services institutions are responding by creating the role of Chief Controls Officer (CCO) to address internal control as a topic in its own right.
In this publication, we assess this development as a response to these challenges. We consider features of the existing landscape that are driving the development of the role, and assess these in the context of the often-unresolved question of the gap between the first and second lines of defence, as well as other gaps and overlaps in coverage that can emerge in the first line.
In particular, we look at these challenges through the lens of the emerging CCO: what are the qualities a CCO needs to address them, what are the success factors they must deliver, and the potential pitfalls when doing so? Many of these questions do not have a single correct answer, but we believe considering them will be of benefit for anyone in the first line of defence who is charged with accountability for risk and control, whether or not they choose to employ a CCO model.
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