Nick Smith of EAM Consulting looks at how firms might structure the oversight and governance of their T&C arrangements.
Firms that are large enough for line management and functions, such as Human Resources, Compliance and managing the T&C arrangements, to be carried out by different individuals should establish a governing body for their T&C arrangements. This “T&C Committee” should meet regularly to carry out the three key activities of:
– Monitoring the effectiveness of the TC arrangements
– Acting as the change control for the arrangements
– Authorising exceptions to the arrangements