Advisers - how do you manage KPI's?

Conrad

:mad:
Just had a voluntary day long compliance visit which threw up a few compliance gaps. We are a mortgage only firm.

With regard to KEY PERFORMANCE INDICATORS I wondered how other small firms make sense of the need to keep and take action in regard to these KPI figures.

For example I was told we need to monitor the proportion of deals that are self cert and put in place compliance action plans that can then be regularly monitored to achieve a desired outcome (read, change).

But what outcome should / could I bring about?

We do not chose who walks through the door. The % of self cert clientelle is what it is:rolleyes:

Any thoughts?


Here's something else to consider; We like all firms pay our Accountants to minimise Taxable income through legal means, which nececitates making expenses appear as high as possible. The complicance officer was bewildered when I pointed out every firm from Tesco down seeks to minimise Tax - anyone would think he came from a parallel universe by his reaction.
So for example we have a directors loan account which is a common method used to reduce corporationTax.

However, the compliance person informed me this means there is then insufficient funds to meet threshold conditions, which is ludicrous as we have a healthy Bank balance (much higher than the threshold level) and no borrowings.

homer_j_3

My network does that through the submission routes.

Do you or your advisers keep a business register? If so incorporate it there - At the end of each month, get the advisers to update the KPI figures that you need.

Dan_Collins_2

Our network provides us with the software at its recorded via submission.

We then talk about it at compliance reviews monthly and quarterly. You can then see and investigate any odd %'s.

But you correct in saying you cannot control who comes through your door!

homer_j_3

Ours go even as far as lender split so the network can ensure that you are not getting too comfortable with a select amount of lenders.

I cannot help on the threshold limit - are you DA then?

The neverending battle of compliance v real world continues..

dunstonh

Networks do all that for network members. Directly authorised have to do it themselves.

If you dont have back office software then add a column to your individual new business registers asking type of mortgage. Then when you do your staff KPIs yearly (or whatever) you can find out what they are individually and at business level.

I looked at going directly authorised a year or two back but decided the cost savings wouldnt be worth the extra compliance and time that was needed.

Dan_Collins_2

homer_j wrote: »

Ours go even as far as lender split so the network can ensure that you are not getting too comfortable with a select amount of lenders.

I cannot help on the threshold limit - are you DA then?

The neverending battle of compliance v real world continues..

Yeah our sounds a bit like that, even repayment method, lender, remo or purchase etc!

HelpWhereIcan

I use MortgageStream which is very good for monitoring KPIs etc not to mention the time it helps to save in processing terms.

Can create a report based on pretty much whatever you want. Had my TCF visit last month (annual visit due in August) and the assessor was shocked when my answer to any question was pretty much instant with respect to business types, lender spread etc etc.

Having said that, my network is soon to start offering The Key for free which is also excellent.

Software is the way IMHO - especially in the days of TCF and principles based regulation.

The outcome you should be looking to bring about is one that ties in with TCF.

For example with self cert, you should be able to evidence that it is only being done in those cases where it is appropriate and that your file shows not only the reasons why self cert was appropriate, but also what other options were considered.

You should be able to show that you have management controls in place to spot potential abuses of your systems or a training need by one of your advisers (not to mention fraud etc by advisers and/or customers).

eg if you spot that the average self cert % for your firm is 20% (mine is 5%) and one of your advisers has 25% with a heavy BM Solutions bias, you should be able to show that you spot it independantly and put steps in place to ensure the cases have been checked to ensure that the right advice is being given and any training is done and/or client disadvantage is put right.

You may actually be doing all this in practice, but can you actually evidence it? As the saying goes "If it's not written down it did not happen."

The capital adequacy one is a doozy and one of the main reasons I am an AR.

http://www.fsa.gov.uk/pages/Doing/small_firms/advisers/resources/poor_advice.shtml

The FSA requirements are over and above the normal accounting standards and other legal requirements, such as the Companies Act, that all companies have to follow. The capital adequacy calculations are designed to ensure that FSA-regulated firms are able to meet liabilities when they are due, especially liabilities for claims from customers. Accounting standards and legal regulations are designed to ensure that financial information is presented in a true and fair manner by companies for their shareholders.

The way it was explained to me is that, although it is often used as a tax mitigation tool, a directors loan account is still a business liability and one that could affect the company's ability to trade if withdrawn.

Not my rule, but I can only think that the FSCS will see many firms that had a healthy bank balance until the directors took steps to wind them up.

minimike2

Network for me too - We use WorkSmart for ours. Also breaks down to each lender / provider.

Re product mix - its fair to say there should be a decent spread of C&I v IO, Fixed v Tracker, and a smaller margin of Self Cert v Status, however if every case is backed up by a fully completed fact find and ROS documenting why the case is as it is then any potential "anomoly" in KPIs becomes immediately and fully justifyable and should not be a cause for concern. (Unless there is malpractice going on).

homer_j_3

HelpWhereIcan wrote: »

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Having said that, my network is soon to start offering The Key for free which is also excellent.

That is what I use to do my back office administration and It is an excellent piece of software. I must say that I am probably using less than 50% of its full potential because I find it too much if that makes sense.

You can do your fact find on there, link your scanner so you can directly scan documents into it and then you put your file notes and it all backs upto a server so you will not lose data.

The ability to create reports, work lists, assign cases to colleagues (if you have multiple people within your organisation) and have diary systems.

It syncs nicely with mortgage brain and it automatically saves your research and illustrations and allows you to produce your reason why letters etc.

Overall, an impressive system but I am waiting for someone to show me how to get more out of it.