The Regulatory Oversight Management role is an additional position within the UK Sub-custodian Regulatory Oversight team with a local reporting line in the UK into the Head of Sub-custodian Regulatory Oversight.
This team reports into the Manager of EMEA CSD & CSD Manager of UK Banking Legal Entities.
The Regulatory Oversight Management role, as part of the UK Sub-custodian Regulatory Oversight team will have responsibility for the management, governance and oversite of appointed affiliate and third party sub-custodians and Central Securities Depositories belonging to the BNY Mellon UK Banking Legal Entities, The Bank of New York Mellon London Branch and the Bank of New York Mellon (International) Ltd.
A top priority of the UK Sub-custodian Regulatory Oversight team is to provide oversight and ensure compliance with UK regulations such as CASS 6 for Custody and CASS 7 for Client Money in addition to ensuring that the ongoing network model and chain of custody is fit-for-purpose.
The Regulatory Oversight Senior Specialist, as an individual and as part of the EMEA CSD team, will take on leadership roles on Corporate and Regional projects that have a dependency on Client Service Delivery and other operational groups in Investment Services and Markets, including the oversight and adoption of new regulations which require a Legal Entity approach. In addition the role will collaborate on UK Legal Entity change management, operational model reengineering and transformation initiatives with particular attention to creating operating efficiency while maintaining a robust control environment.
Key Responsibilities
- Initial and ongoing due diligence of the UK Banking Legal Entity sub-custodian / CSD network, including detailed validation of completed due-diligence in line with UK CASS rules.
- Ensure that the UK LE Network is in compliance with all relevant UK regulations.
- Ensure that UK regulatory risks for specific business /client activities are identified and that an appropriate control environment is developed to manage and mitigate those risks arising from UK Sub-custodian Regulatory Oversight.
- Review internal and external audit, compliance and risk reports in respect of UK Sub-custodian Regulatory Oversight and implement actions required in compliance of UK regulations.
- Develop and manage Service Level Descriptions /KPI to monitor sub-custodian / CSD service delivery.
- Monitor and ensure that new accounts (firm and client accounts) with external sub custodians and third party banks are established with the appropriate BNYM Entity.
- Ensure that safe custody assets are only deposited with custodians in jurisdictions which specifically regulate and supervise the safe keeping of safe custody assets in line with the UK Regulatory requirements.
- Ensure that no lien letters / no lien wording is in place for all sub custodian contractual agreements and associated depot accounts, that these meet the UK Regulatory requirements and that a copy is kept for all accounts.
- In conjunction with Legal, ensure that custodian agreements are in place for all accounts and that these agreements include the relevant contractual clauses in accordance with UK Regulatory requirements.
- Ensure that all custodian and third party bank agreements are maintained and recorded and that a copy is stored in a central repository.
- Monitor credit ratings and escalate any drop to COOC and UK LE Risk Management Committees
- Ownership and maintenance of the UK Network for the purposes of the CASS RP and the annual CASS audit (due diligence, sub-custodian contracts/agreements)
- Provision of regulatory advice and oversight of ‘the Firms’ nominee network
- Coordination of ‘the Firms’ nominee network, including:
- Advice to Lines of Business on the establishment and use of nominees by the UK regulated entities
- Endorsement of new, or the dissolution of redundant, Nominee companies within the ‘Firms’ network’
- Focal point for maintaining centralised records of the ‘Firms’ nominee activities, including a nominee matrix and structural diagram for ‘the Firms’ nominee network
- Provision of a central point of coordination and authority for internal and external enquiries for nominees, specifically those relating to regulatory issues
- Establish and maintain controls to ensure that Firm and client assets remain segregated by nominee in UK and Irish markets
- Liaison between Company Secretariat, Nominee Directors and Securities Operations teams
- Provide CASS RP delegate functions for nominee deliverables relating to CASS regulations.
- Review and validate of monthly registration matrix for the CMAR and RP
- Act as the named Responsible Individual within the CASS Accountability Matrix and provide oversight for CASS compliance and the production of CASS related MI.
- Represent UK Sub-custodian Regulatory Oversight at Board, Management and Legal Entity Committees
Ensure that a strong risk management and governance culture is embedded within the Business Unit by promoting the ‘Three Lines of Defence’ model (by working collaboratively with the Second and Third Lines of Defence to identify risks, conduct root-cause analysis, implement remediation activities and to communicate lessons-learned findings) and by developing and implementing strong risk practices across the Business Unit (including the use of the RCSA as the key management tool to actively manage risk within the Business Unit).
Risk Competence & Knowledge – Understand the Business Unit’s Risk Appetite and how this relates to the legal entity infrastructure and the legal entities under which the Business Unit operates and the legal entities through which the Business Units’ client(s) contract and the impact that this has on the Business Units’ regulatory operating environment.
Accountability – Ensure that responsibilities related to risk management are clearly defined and understood throughout the Business Unit to ensure that risks are identified, escalated and remediated in an effective and transparent manner.
Other Risk Management Responsibility – Ensure that Business Unit operating procedures and other key directive controls (eg. checklists) are maintained on a regular basis to ensure that they are adequately designed, continue to be an effective risk management tool and are being used as required.
Throughout continued and effective oversight, ensure that appropriate Key Risk Indicator (KRI) measurements and tolerances are in place and are agreed with Senior Operations managers and LoB Risk Management.
Qualifications
Good knowledge of the UK Regulatory (CASS 6 & 7, SYSC, COBS) requirements. Proven organisational and Project Management skills. Strong written and verbal communication skills. Proven previous experience within an Operations role. Financial Services experience essential Previous Network Management experience desirable but not essential.
Benefits
- Annual Holiday – 25 Days, plus bank holidays and the ability to purchase a further 5 days
- Pension – 12% employer contribution
- Life Assurance, Income protection and Medical Insurance
- Education Assistance
- Childcare Vouchers
- Health screening
- Season ticket loans
- Recognition and service awards
- 2 volunteering days per annum
For over 230 years, the people of BNY Mellon have been at the forefront of finance, expanding the financial markets while supporting investors throughout the investment lifecycle. BNY Mellon can act as a single point of contact for clients looking to create, trade, hold, manage, service, distribute or restructure investments & safeguards nearly one-fifth of the world’s financial assets. BNY Mellon remains one of the safest, most trusted and admired companies. Every day our employees make their mark by helping clients better manage and service their financial assets around the world. Whether providing financial services for institutions, corporations or individual investors, clients count on the people of BNY Mellon across time zones and in 35 countries and more than 100 markets. It’s the collective ambition, innovative thinking and exceptionally focused client service paired with a commitment to doing what is right that continues to set us apart. Make your mark: bnymellon.com/careers.
Client Service Delivery (CSD) brings together BNY Mellon’s key operational areas into one global team to better support the company’s businesses and serve clients around the world. CSD helps clients to conduct business, service assets, and engage in transactions in 35 countries and more than 100 markets. At every stage of the investments lifecycle – creating, trading, clearing, settling, holding, servicing, managing, distributing and restructuring assets – CSD is working to make BNY Mellon the recognized industry service quality and productivity leader. Client Service Delivery manages investment monitoring, measurement and processing services for our clients. Our solutions include Securities Operations, Fund Administration, Transfer Agency, Outsourcing, Performance Measurement and other related services.
BNY Mellon is an Equal Employment Opportunity Employer.
