gap hunter.


Our Gap Hunter service is structured around a questionnaire and workshop and is available in both fixed price and free of charge service options.


At the end of the Gap Hunter process you will know where you have areas of risk within your SMCR implementation and you will have a clear set of short term actions to remove this risk.


The end result is that you will be able to demonstrate that you have taken all reasonable steps to comply with SMCR in the event of a regulatory investigation.  

1  Before the Workshop

We send you a pre-workshop questionnaire that is designed to give us a fast and effective scan of your SMCR implementation and to draw out areas of focus and priority for workshop.

We have built and refined the questionnaire over time - it is quick and easy to complete and is largely self explanatory. We will be available at any point should you need help in completing it - 90% of our clients manage without us. 

The Workshop

Let’s assume that step 1 shows risk around the way that your firm handles requests for regulatory references.  We will focus in on regulatory references in the workshop and stress test your process against a selection of realistic "what happens if.." scenarios.

It quickly becomes evident when a scenario causes your process to break down - we then tease out the underlying causes of the breakdown. These may include things such as unclear escalation processes, a lack of staff training, poor documentation, ineffective performance measures etc. 

3  After the Workshop

This approach means that we can give you practical and specific recommendations based on good practice that you can implement quickly – we call this a Risk Action Plan (RAP). We create the RAP immediately after the workshop and then take you through it step by step in an online meeting. 

The scope of the RAP can include changes to documents, processes, supporting IT, organisation and training. It will also include clearly laid out steps for delivering each recommended change.

We also offer further support in the form of review meetings to assess your progress against the RAP recommendations and to provide help to overcome any challenges that you may be facing. 



Option 1  Gap Hunter Questionnaire
This option suits firms that are looking for a fast turnaround risk assessment of their SMCR implementation based on on our SMCR pre-workshop questionnaire.  It includes the following:

  • We provide the questionnaire, you complete it and we provide whatever support you need to do this.

  • We deliver a high level Risk Action Plan based on the answers you have provided in the questionnaire.


Price:  Free of charge

Option 2  Gap Hunter Workshop and Support


This options suits firms who want to investigate possible areas of SMCR risk in greater detail and have the assurance of further support as you implement our recommendations. It includes the following:

  • We provide the questionnaire, you complete it and we provide whatever support you need to do this.

  • We set up and run a 2 hour workshop to explore your areas of risk in more detail and to discuss possible actions. 

  • We deliver a detailed Risk Action Plan based on the outcomes of the workshop and the questionnaire. 

  • We provide a 1 hour online meeting to discuss the RAP and to ensure your full understanding of our recommendations. 

  • We provide an additional review and support meeting at an agreed point to assess your progress against the RAP and to help with any challenges you may be facing. 

Price:  £5000


case study.

The Firm

Our client is an asset management firm with over 500 employees. 

The Gap

The initial questionnaire highlighted concerns around the identification of certification staff and, in particular, that individuals who needed certification may be missed, leaving the firm exposed. 

We explored this further through the Gap workshop and it became clear that our client did not have any consistent definitions around certain Significant Harm Functions such as "Significant Management Certification Function". 


This meant that there were different views in different parts of the firm's operation about the scope of these roles and therefore which individuals were in scope of certification. 


Our main recommendations were that:

  • Our client created a consistent taxonomy of SMCR terms including clear definitions for all Significant Harm Functions. For example, in the  case of "Significant Management Certification Function" this meant agreeing the detail around what defines a "significant business unit" including factors such as risk profile of the unit, the unit’s use of the firm’s capital, number of customers served by the unit etc. 

  • The compliance department led the creation of the taxonomy but with the support and involvement of heads of business units and HR.

  • The taxonomy was held in a central repository and read only access was provided to all relevant staff.

  • The taxonomy was a living document that was underpinned by a clear change management process owned by the compliance department. 

  • Updates to the taxonomy were communicated throughout the organisation. 


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