This service provides a Register of Rulings for all interpretation issues relating to the legal content of any regulations. It provides a structured way of consolidating and maximising the value of legal contributions and includes a log of proceedings that provides the due diligence for a client’s position if challenged by a customer, regulator or the court.
Practical Application of Regulations
Companies make the mistake of thinking that you can take a regulation, whether it is a piece of legislation or international standard your company must comply with, and train staff, or send out a gap analysis questionnaire, without first understanding how it applies practically to their operations. In many instances, regulations are written generically to apply across a broad spectrum of businesses and therefore requires specific interpretation by a company before it can be applied correctly. The bottom line is that you need everyone to be “singing off the same hymn-sheet” before embarking on gap analysis or training.
Structure and Approach
To this end, we have a service whereby new, or changes to existing, regulations that require to be analysed by a company, go through a structured process of resolving any interpretation issues with the appropriate stakeholders dealing with the regulatory change. It involves doing a page-turn analysis to unpack the requirements and log the issues with a special forum we set up for the purpose called a Legal Standing Committee.
Singing Off the Same Hymn Sheet
Once resolution is reached on an interpretation issue, it is captured in a Register of Rulings (ROR) for that regulation. The research, deliberations and decisions taken in committee, leading up to the ruling, are also logged as evidence and provides a form of due diligence that can be used to support the position taken by the company if challenged by a customer, regulator or the court. The ROR becomes the company’s set of interpretations and ensures everyone is singing off the same hymn sheet for that particular regulation.
Integration with Other Services in the Portfolio
These RORs belong to the library of regulations that are part of our Regulatory Universe Register solution in the COMPLY module of T-GRCS. Without these rulings you are stuck with the “vanilla” version that is available to the broader public and this is not good business practice. This is because it fails to achieve a key regulator requirement of being able to prove you have internalised their regulations. There should be an annexure to every core regulation that provides the company’s interpretation of the regulation in the form of our GRC Standard’s ROR.
Our GRC-POS-01 service that deals with the digitisation of regulations and detail level requirements (DLRs) is the first place where we would pick up the interpretation issues that would then go to the LSC for processing so these two services work together normally. Then, when carrying out the gap analysis and risk assessment of the regulatory changes under GRC-POS-24, these rulings are flagged against the relevant DLRs so that they are factored into the analysis. At the same time, any new insights gained during the analysis may raise further interpretation issues that are processed through the LSC in the same way.
Request for Information
Should you wish to find out more about this or any of our other Portfolio of GRC Services or Solutions, please don’t hesitate to give us a call or email us. Our details can be found at the bottom of this screen or under Contact on the main menu.