Today, UK embedded finance platform provider BaaS is available. Griffin, announces it has adopted Clausematch compliance technology is used to create and review all documentation necessary to submit an application to the PRA or FCA in order to become a licensed bank. This is a crucial proof-point to support the adoption RegTech software in order for efficient bank licensing for modern FinTech businesses.
Clausematch has been instrumental in helping Griffin manage this complex and long process. To submit the documents to the PRA or FCA for licensing, the documents must be approved by both management-level and board level committees. This means that policies are continually being revised in response to feedback from executives and board members.
The application pack includes over 100 documents. These include policies, terms of reference, plans and procedures. 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.
Multiple authors and approvers are required to input these documents from different business areas, such as finance, risk, compliance and engineering. After the drafting stage has been completed, all documents need at least two rounds to be reviewed and challenged before final approval.
“All of the materials we submit must go through a precise governance process,” Rupert Whitten is Chief Operating Officer of Griffin.. “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.”
Documents need to be approved both by a management and board committee. As such, policies are continually being updated in response to executive and board comments.
The Griffin team stated that each paragraph had its own comment trail, which made it easier to make changes and to review them. Clausematch gives Griffin a complete record of every change made and their reasons.
“In particular, the versioning function is very useful. It provides a complete history of the document in the document itself,” Whitten. “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.”
Marianne Cassidy, Griffin’s in-house writer, was tasked with ensuring there was a cohesive narrative throughout the pack, as comments were addressed and changes were made.
“For longer documents, coordinating edits across five or six different authors was a nightmare. Work was getting lost or not syncing correctly, we’d have to jump on calls to sort out multiple conflicting edits. People were creating new drafts, saving things in the wrong folders, or saving them in them locally and uploading later, which meant stakeholders ended up working from different versions at one point,”Cassidy explains. “Clausematch effectively eliminated those challenges.”
“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,” Cassidy. “None of us have ever lost any work on Clausematch, and that alone is a big benefit.”
Griffin’s culture places a lot of importance on good writing and with so many moving parts, it is crucial that every document in the pack has a clear and consistent message. Collaboration in Clausematch helped the team produce high quality work. It forced them to think carefully about how they structured documents.
“You can’t just chop and change things the way you can in other document editors.When you move or delete something, Clausematch encourages you to think about the “why”,” Cassidy. “It reduces the chaos factor and enables us to implement a consistent structure across our policies, which makes our documents more readable.”
Emma Kempton, Clausematch’s VP Customer Success, stated:: “We’re delighted to be working with Griffin. Our relationship was mutually beneficial. We supported them in applying to their bank licence using our tooling. However, the Clausematch product teams also learned a lot from Griffin regarding the requirements of organisations at this stage in their journey. Griffin created the documents using our platform entirely from scratch and received invaluable feedback regarding product features. We are looking forward to many more years of our collaboration.”
Griffin submitted their bank authorisation request on May 12th. But, the journey isn’t over. Griffin will continue to submit documentation to regulators in order to make sure the bank is ready to serve its customers when it becomes fully regulated.
“Our policies and procedures will evolve and change as Griffin does, and in response to new regulations and best practice.” Whitten. “Clausematch ensures our governance process remains clear and transparent, and we have a central source of truth as the company grows.”
Griffin plans to use Clausematch as the primary tool for maintaining and drafting policies. He is also considering using Clausematch to manage the policy attestation process in the future.
“Our documents are born on Clausematch and they stay on Clausematch. We don’t see that changing in the future,” Cassidy.