Risk factors we consider when setting your review date
Since 2024 we have moved to a more risk-focused cycle for most IPs. This means we begin pulling together our monitoring schedule using a six-year baseline. This is then adjusted using a range of risk factors, including:
- the outcome of your previous visit;
- your disciplinary record/complaints history;
- if the scope of your previous visit was limited due to your portfolio at the time;
- the size and mix of your portfolio;
- any adverse publicity;
- a move to a firm of which we have no previous regulatory experience;
- your involvement in any high-profile cases; and/or
- other intelligence, including your responses to our annual return and information provided by other regulators.
Where your most recent routine monitoring visit was referred to ICAEW’s Insolvency Licensing Committee (ILC) your next visit is likely to be accelerated. That will be the case whether or not there’s any formal finding from the committee’s consideration of the report.
Where your most recent visit required some follow up - for example we may have asked to see your next insolvency compliance review or to have followed up on a number of specific issues, then again, your next visit may be on a shorter cycle.
Factors that will not affect your normal review cycle
Where there has been ongoing correspondence with the ILC or our colleagues in the Conduct Department, this doesn’t alter your visit cycle. A targeted visit ordered by the ILC also is separate from your routine monitoring visits as a targeted visit will generally have a limited scope.
Working with you whilst fulfilling our regulatory responsibilities
We do understand that dealing with ongoing issues and accommodating us for a monitoring visit can be stressful and time consuming. We are always willing to work with IPs to ensure that proposed visit dates work for them so that they and key staff will be available. However as your regulator, ICAEW is responsible for determining the appropriate visit cycle for each IP.
Where IPs resist having a visit scheduled, we may have to refer them to the Insolvency Licensing Committee.
