ARROW

ARROW is an FSA Acronym standing for the Advanced Risk Responsive Operating frameWork. It is the primary process and tool through which the FSA assesses the risks and compliance requirements appropriate to each firm. An ARROW visit is a regulatory risk assessment involving an intrusive and searching examination of a firm and its business.

Prior to the ARROW Preparation visit, the FSA will:

• send a pre-visit list of documents, which they will require prior to the visit;
• provide a list of documents required to be available at the visit itself;
• identify key people who must be available for interview during the visit.

The ARROW Preparation visit will normally last for between 1 and 3 days and will be conducted by at least two people from FSA, who are experienced in the ARROW visit process. At least one of them will normally be a fairly senior manager. They will interview the key managers/personnel and probe with them their understanding of their own and the firm’s regulatory responsibilities, particularly under the FSA Senior Management Systems and Control rules (SYSC). 

The ARROW visit will normally result in brief oral feedback at the end of the visit followed by a detailed report setting out any remedial actions required by FSA. The FSA will give a risk rating for the firm based upon the FSA’s four Statutory Objectives and their key risk areas. The higher the risk rating the greater the regulatory and supervisory scrutiny that FSA will impose on the firm.

For all firms subject to this type of challenging experience it is essential that they are well prepared and have a detailed understanding of the process, the FSA’s expectations and desired outcomes. It is key that a firm’s senior management are well prepared for this visit and are able to provide a robust and joined up strategy in handling the visit. 

Within Resources Compliance we have the appropriate experience and resource to help firms prepare for their FSA ARROW visit by giving them a realistic taste of what the FSA is likely to explore with them, how it will be undertaken and the kind of responses they will need to provide to manage the visit efficiently and provide the FSA with comfort that the firm’s strategy is aligned with its regulatory responsibilities.

We can carry out both pre and post ARROW visits in order to prepare firms for the FSA visit as well as providing post ARROW assistance in implementing FSA recommendations having acted for a number of firms in this capacity.