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Quality Management (Firm Level)

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Presentation on theme: "Quality Management (Firm Level)"— Presentation transcript:

1 Quality Management (Firm Level)
New York December 12, 2018

2 Identification of Quality Risks
Para 22(q) Para 31(a) Para 31(b) Significant individually Reasonably possible Quality risks (whole universe) Identified quality risks Significant in combination Not reasonably possible Not significant No further procedures required

3 Assessment of Quality Risks
Highly Likely Para 31 Para 32 Identified quality risks QR3 Possibility of occurrence QR1 QR2 May have a significant effect on the achievement of a QO Very Significant Effect of quality risk on quality objective (magnitude)

4 Objective of the Standard
Designing Responses Objective of the Standard Establish quality objectives QO 4 QO 1 QO 2 QO 3 QO 5 QO 6 QO 7 QR 1 QR 2 QR 3 Higher Lower Lower Resp. 1 Resp. 2 Resp. 3 Resp. 4 Para 32/33

5 Determining Whether a Finding is a Deficiency
Monitoring activities (Para 46) External inspection Other sources Findings (Para 49) Positive findings Negative findings – evaluate to determine whether deficiencies exist (Para 49A) Factors to consider: (Para A174) Nature of finding Design of monitoring activity Extent of monitoring activity Extent of findings in relation to population If finding relates to a response: Nature of quality risk Other responses addressing quality risk Indication of a trend or systemic issue Deficiencies Root cause Effect of deficiencies Remedial action (Para 50)

6 designed / not effective
Deficiencies Objective of the Standard Establish quality objectives QO 4 QO 1 QO 2 QO 3 QO 5 QO 6 QO 7 QO 8 Missing QR Missing QR Missing QR QR 1 QR 2 QR 3 Missing Resp. Higher Higher Lower Lower Missing Resp. Missing Resp. Resp. 2 Resp. 3 Resp. 4 Missing Resp. Resp. 1 Missing Resp. Inadequately designed / not effective 33. The firm shall design and implement responses to address the assessed quality risks, including the responses required by this ISQM. The design of the responses shall be based on, and responsive to, the reasons for the assessments given to the quality risks. (Ref: Para. A46–A47, A57–A62) The red items represent deficiencies in the initial analysis: Resp. I was found to be inadequately designed Resp. I alone did not adequately address QR 1, therefore an additional response was added A QR and Response were not identified / assessed / designed QO 8, the related risks, and the related responses were omitted Para 50

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