Visibility is not ownership.

The Central Bank has asked every fund management company to do two things before year end: gap-analyse its delegation arrangements against July’s thematic review, and test its compliance and internal audit functions against the CSA feedback.

We run both reviews independently — separately or as one. Delivered as a board-ready plan with a rated finding, an owner and a deadline against every gap.

The Gap Review

About the firm

Vantage Point Partners advises regulated financial services firms — management companies, investment firms, fund administrators and digital asset service providers — on governance, control frameworks and regulatory engagement.

Small on purpose

A partner does the work, and the same partner attends your committee. Our clients include standalone Irish firms and the Irish entities of global groups. We have led several reviews of regulated firms required by the Central Bank of Ireland, and because we do not audit the firms we assure, we can take work the large firms are conflicted out of.

Our founder, Paul Traynor
Managing Partner

Paul has spent more than thirty years in and advising financial services, on both sides of the table. He led EY’s Wealth & Asset Management Consulting practice and PwC UK’s Investment Management Consultancy practice, and headed EisnerAmper Ireland’s governance, risk and compliance teams. Inside the industry, he was a managing director at BNY, heading its Pensions and Insurance client segments internationally. He has chaired Irish Funds’ Internal Audit Working Group and sat on EFAMA’s Fund Regulation, Asset Protection and Service Providers Standing Committee. Chartered Accountant, B.Comm (UCD), and a current Central Bank approved PCF.

What we do

Our practice is built around independent second- and third-line assurance for regulated firms — internal audit and control-function review, delivered to the board. Everything else we do sits either side of it.

Protect

Independent second- and third-line assurance. We test your compliance and internal audit functions from outside them, against the Central Bank’s CSA and delegation feedback, and we deliver the result as a board-ready remediation plan.

  • The Gap Review — three weeks, fixed fee
  • Outsourced and co-sourced internal audit — retainer, including fractional PCF-13
  • Pre-inspection preparation (PRISM, SREP)
  • Risk Mitigation Programme issue resolution and complex regulator interactions
  • Designated Person and independent non-executive director appointments
Optimise

Once the control environment is sound, the question becomes what it costs to run. We review operating models and the cost of servicing regulated activity, and design frameworks that scale without adding headcount.

  • Target operating model review
  • Cost-to-serve across regulated operations
  • Control framework design and simplification
  • Outsourcing and delegate oversight
  • Harnessing group policies and processes to cut duplication while meeting local obligations
Grow

Growth in a regulated business is a governance question before it is a commercial one. We support authorisations, new market entry, and owners making decisions about regulated platforms.

  • Authorisation and new-entity set-up
  • New market and new permission entry
  • Operational and regulatory due diligence
  • Post-acquisition integration

Who we serve

Our practice is built around independent second- and third-line assurance for regulated firms — internal audit and control-function review, delivered to the board. Everything else we do sits either side of it.

Fund management companies and AIFMs
  • The 31 December remediation deadline applies to you directly
  • Internal audit activity outsourced to Group
  • Frameworks approved at Group before the local board sees them
  • Group risk ratings that thin local coverage
MiFID investment firms and wealth managers
  • Wealth managers, online brokerage, stockbrokers and pensions servicing
  • A second line that has grown more slowly than the business
  • Suitability, conflicts and client asset obligations under continuous supervision
  • Regulatory due diligence on both sides of a transaction
Fund administrators and corporate service providers
  • Multiple regulated entities across jurisdictions
  • A board and an assurance obligation for each of them
  • One governance function stretched across all of it
Payments, e-money and digital asset firms
  • Fast-growing and heavily supervised
  • Building the control environment while the business changes shape
  • MiCA, CASP and payment institution permissions
Owners of regulated platforms
  • Private equity sponsors and boards mid-integration
  • Independent comfort on the control environment
  • Not a management assurance that it is fine

Sample engagements

A selection of the work, described without naming clients.

1
Acting as the outsourced internal audit function for a regulated firm in Ireland, reporting into its risk and audit committee.
2
SOC 1 and internal audit services to MiFID firms, captive and third-party ManCos, wealth and asset managers, depositaries and fund administrators.
3
Reviews of regulated firms required by the Central Bank of Ireland, including outsourcing and risk management frameworks.
4
Independent assessment of second- and third-line effectiveness ahead of supervisory engagement.
5
Advising a major investor servicer on its third-party and inter-group cross-jurisdictional outsourcing arrangements.
6
Leading a multi-year administration restitution-of-control project for a major global custodian, overseen by the regulator.
7
Technology, operations and regulatory due diligence of one of the largest third-party ManCos (ACD) in Europe, ahead of a strategic investment by a private equity firm.
8
Design of a governance and control framework for a newly authorised firm.
9
Target operating model and cost-to-serve review across a multi-jurisdiction regulated business.

Delegation and control functions: two reviews, one deadline

The delegation review carries the hard date: a time-bound remediation plan in place before the end of 2026. The CSA feedback asks for time-bound plans without naming a date, with follow-up through ongoing supervisory engagement. Year end is the sensible anchor for both, and a review needs to start by early November to be board-approved in time.

Talk to us

Start with a conversation about your second and third lines

If the Central Bank’s feedback has landed on your board agenda and nobody has yet worked out who runs the gap analysis, that is the conversation to have.

Address
Vantage Point Partners
26/27 Upper Pembroke Street
Dublin 2
D02 X361
Why Choose Vantage Point Partners?
  • Over 30 years of senior industry experience
  • Pragmatic, actionable solutions
  • Cost-effective boutique approach
  • Proven track record with global institutions

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