Today, UK BaaS and embedded finance platform provider, Griffin, announces that it has adopted Clausematch compliance technology for drafting and reviewing all the documentation required to submit its application to the PRA and FCA to become a fully licensed bank.
This is a critical proof-point for the adoption of RegTech software for the efficient approach to bank licensing for modern FinTech companies.
Clausematch has so far been instrumental in enabling Griffin to smoothly manage this long and often complex process. In order for the documents to be submitted to the PRA and FCA for licensing, they must be approved by a management-level and board-level committees, which means policies are constantly being iterated on in response to comments from board members and executives.
The full application pack consists of over one hundred documents, including policies, terms of references, plans, procedures, and assessments. Some key documents, such as the company’s Regulatory Business Plan and its liquidity and capital assessments, are hundreds of pages long and require exceptional attention to detail. These documents require input from multiple authors and approvers across different areas of the business, including finance, risk, compliance, engineering, product, and commercial operations. Once the drafting stage is complete, all documents require at least two rounds of review and challenge, before final approval.
Rupert Whitten, Chief Operating Officer at Griffin commented on the decision to adopt Clausematch technology: “All of the materials we submit must go through a precise governance process. The regulators require applicants to demonstrate there has been robust challenge throughout the entire drafting process, and Clausematch gives us very clear and granular evidence that this happened and when. In particular, the versioning function is very useful. It provides a complete history of the document in the document itself. All the different versions are at the same link, in the same folder, and you know everyone is working on the correct material - it's hugely helpful."
Clausematch technology provided Griffin with a rigid and structured platform that minimised the formatting options available for the user. This ensured that Griffin employees were more organised from the beginning of the process. As the technology ensured a collective approach to editing documents, a granular perspective was provided, rather than a large amount of data to consume at once.
Marianne Cassidy, in-house writer at Griffin who was tasked with ensuring there was a cohesive narrative throughout the pack, said: “I love that you can’t make edits offline or edit a paragraph that someone else is working on - it’s physically impossible to create conflicting changes, which is so important when you need a very precise audit trail.”
Emma Kempton, VP Customer Success at Clausematch, said: “We’re delighted to be working with Griffin. Our relationship has been mutually beneficial as not only have we supported them in applying for their banking licence with our tooling, but also along the way the Clausematch product team learnt a great deal from the Griffin team, in terms of the requirements of an organisation at this stage of their journey. Griffin created their documents on our platform from scratch, and their feedback in terms of product features has been invaluable. We are looking forward to many more years of our collaboration.”
Griffin officially submitted their bank authorisation application on May 12, but the journey is not over. Griffin will continue to submit documentation and work with regulators to ensure the company is in the best position to serve its customers well when it becomes a fully regulated bank. The Clausematch platform will provide Griffin with the opportunity to establish a compliance infrastructure to ensure future documentation submissions are done with ease.