Regulation

COBAC: the reports to prepare before the inspection arrives

Which returns the regulator expects from you, how to organise them throughout the year and avoid a last-minute rush on the day.

Elmo's Team7 min read

When an inspection is announced, teams often run into the same difficulties: scattered data, documents that cannot be found, figures that do not match from one return to the next. The surest way to avoid this last-minute rush is to prepare all year round, through small, regular habits.

Why start well in advance

A regulator does not only judge the content of a return, but also the institution’s ability to produce it, justify it and find it again. An institution that prepares its filings at the last minute multiplies the risk of error, and no longer has time to check.

Conversely, continuous preparation turns the inspection into a simple verification: the figures have already been checked, the supporting documents are filed, and everyone knows what they have to present.

Five habits to adopt

  • Keep a calendar of filings, shared by compliance, finance and management.
  • Name a person in charge and a deputy for each return.
  • Check consistency between returns before each submission, and not only the accuracy of each one on its own.
  • Keep, for every figure, the document that supports it, filed so that it can be found.
  • Keep a record of every validation: who approved, when, and which version.

Who prepares what, and when

A clear split of roles prevents omissions. Here is a simple example, to adapt to your institution’s organisation.

StepPerson responsibleWhen
Calendar of filingsComplianceStart of the year
Collection of source dataEach departmentEach period
Consistency checkFinanceBefore each submission
Validation and signatureManagementBefore the deadline
Archiving of supporting documentsComplianceAfter each submission

The mock inspection

Once a year, simulate the arrival of an inspector. Pick a period at random, ask your team to find the corresponding returns, their supporting documents and their validations, and time the exercise.

What you cannot find within ten minutes during the exercise, you will not find on the day of the inspection either.

Then note the gaps: missing documents, undated validations, diverging figures. Correct them before the real deadline.

What your teams take away

  • A shared calendar is better than individual memory.
  • A filed supporting document is an answer that is already prepared.
  • A mock exercise costs half a day, and saves several.

A suitable tool makes all of this easier, by keeping a record of every operation and preparing the returns from your data. But team discipline remains the first form of protection.

Elmo's Financial Solutions teamOur teams support banks, microfinance institutions and organisations that collect funds, from go-live to regulatory follow-up.
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