Griffin adopts Clausematch for optimal version control and transparent governance during its bank authorisation application process
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.
“All of the materials we submit must go through a precise governance process,” Rupert Whitten, Chief Operating Officer at Griffin said. “The regulators require applicants to demonstrate there has been robust challenge throughout the entire drafting process, and Clausematch gives us very clear and granular evidence that this happened and when.”
Documents have to be approved by a management-level committee and a board-level committee, which means policies are constantly being iterated on in response to comments from board members and executives.
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.
“In particular, the versioning function is very useful. It provides a complete history of the document in the document itself,” Whitten said. “All the different versions are at the same link, in the same folder, and you know everyone is working on the correct material – it’s hugely helpful.”
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.”
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.
“Our policies and procedures will evolve and change as Griffin does, and in response to new regulations and best practice.” Whitten said. “Clausematch ensures our governance process remains clear and transparent, and we have a central source of truth as the company grows.”
Griffin intends to continue using Clausematch as its primary tool for drafting and maintaining policies and is considering running the policy attestation process through Clausematch in the future.
“Our documents are born on Clausematch and they stay on Clausematch. We don’t see that changing in the future,” Cassidy said.