Clausematch’s policy management platform helps Banking as a Service (BaaS) provider, Griffin, complete an important step towards securing a UK banking licence; submitting its authorisation application to the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA).
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 also 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 gothrough a precise governance process. The regulators require applicants todemonstrate there has been robust challenge throughout the entire draftingprocess, and Clausematch gives us very clear and granular evidence that thishappened 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 knoweveryone is working on the correct material - it's hugely helpful."
The Griffin team highlighted that having individual comment trails attributed to each paragraph made it easier for the team to work through changes as each document passed through review. With Clausematch, Griffin has a detailed record of each change made and why.
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 said. “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. The team found that collaboration in the Clausematch editor helped produce quality work by forcing the team to be thoughtful about how they structure documents from the outset.
“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 said. “It reduces the chaos factor and enables us to implement a consistent structure across our policies, which makes our documents more readable. Our documents are born on Clausematch and they stay on Clausematch. We don’t see that changing in the future.”
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 complianceinfrastructure to ensure future documentation submissions are done with ease.