The FCA’s approach to Risk Frameworks & Wind Down Plans 

12/09/2023 | Online Zoom Conferencing

The briefing will cover observations on recent developments in the FCA’s approach to TC2.4 Adequate Resources; specifically Risk Frameworks and Wind down plans.
It will include:

  • Re-cap of what TC2.4 and Wind down planning is and an overview of the evolution of the FCA’s expectations
  • Insights into topical issues i.r.o both RF and WDP
  • Select examples of best practice in terms of:
    • Linking wind down triggers with risk framework and appetite
    • Financial stress and reverse stress testing
    • Non-financial resources stress testing
    • The process for preparing a WDP and liquidity model

Learning Objectives

At the end of this session, delegates will be able to:

  • Outline the importance of TC2.4 and explain where in the FCA guidance to look for information
  • Describe the focus areas when reviewing your own WDP
  • Summarise some of the best practices
  • Outline the link between wind down triggers and the risk framework in practice
  • Explain market practices on stress and reverse stress testing for financial and non-financial resources

About the Presenters

Bradley Chadwick

Partner, Financial Services Restructuring and Insolvency


Bradley is an internationally experienced finance and restructuring executive with a successful record in both industry and as an advisor.  Bradley has served in roles including CFO, COO and interim manager. Bradley has worked for a number of stakeholders including Boards, the Executives, lenders, and regulators.


The Grant Thornton UK LLP lead for Insurer and Asset Manager Wind Down Planning and Recovery & Resolution engagements.  In this role he has led multiple engagements either reviewing or preparing WDP’s for Global Insurance Brokers and other FS entities.

CFO and COO of Scottish American Capital, a private equity fund with a portfolio of companies in the insurance intermediaries. Bradley provided strategic leadership and direction for the Board of the private equity fund, he also had a leadership role with portfolio entities including M&A, post-merger integration and performance improvement.

Led the team which guided a public US carrier through the carve out and stand up of a $19BN annuities business which it sold to a hedge fund.

On behalf of a Carrier led a team preparing WDP for an MGA which had distributed over 5 million of its policies.

Retained by a lender to conduct an IBR of an insurance group (including carrier and broker) and take a Board Observation role.

Klaas de Vries

Director, Actuarial and Risk Management


Klaas is leading Grant Thornton Insurance Risk Management practice. Klaas has 25 years experience in the financial services industry with a focus on insurance. Klaas has served in roles including CRO, Audit Director and various technical specialisms before.


The Grant Thornton UK LLP lead for Insurance Risk Management services focussing on the life and general insurance markets as well as the brokerage market. He led multiple risk and capital management engagements to multi-national and medium sized clients in the UK market. This includes advising brokers on the risk management aspects of Wind Down Planning.

Led large IFRS 17 implementation engagements to multi-national insurance groups in the UK and European markets.

Chief Risk Officer of a major division of large South African based insurance group where he focussed  risk and capital management.

Established and led the Actuarial, Finance and Investments Internal Audit team at a large South African based insurance group.

Led implementation of Solvency II at a large South African based insurance group.

Provided risk advisory services to various international insurance clients during his professional services career.

Shane Smith

Director, Financial Services Restructuring and Insolvency


Shane has worked for the Grant Thornton network in restructuring and insolvency both in the United Kingdom and Australia for approximately 17 years.

Since joining Grant Thornton in 2004 he has assisted on engagements with lenders, regulators and corporates in a variety of formal and informal engagements such as external administrations, pre-lending and investigative business reviews, viability assessments and wind-down planning.


Led on the wind-down and mitigation planning for a significant MGA and Broker in the UK market. In this role GT was representing a Carrier and in addition to detailed and practical wind-down planning to mitigate policyholder detriment, the impact on the market and the effect on the carrier we engaged with the FCA to consider the plans.

Shane led contingency and wind down planning (including TC2.4 considerations) work streams on a number of significant financial services engagements (many of which are not public). The public ones being Brighthouse (which has an insurer subsidiary) and Greensill Capital.

In 2011 and 2012, Shane was placed on secondment to the credit department of Australia’s largest business bank, where he predominantly worked on turnaround files with distressed debt levels of up to AUD$20m.

Toby Dewar
Assistant Manager, Restructuring and Insolvency


Toby has worked for Grant Thornton UK LLP for five years, spending four years in the audit department and one year in Restructuring and Insolvency. Toby is a qualified Chartered Account and became a member of the Institute of Chartered Accountants in England and Wales (ICEAW) in August 2021.

He attended the University of Sheffield, where he obtained a degree in Economics in 2017.


Supported on four wind-down plan projects for insurance brokers. The services provided ranged from producing a report on our findings for their board, to formalising a roadmap and plan for a firm to complete their first wind-down plan.

Developed a “Toolkit”, which is a best practice tool on producing a wind-down plan. This tool has helped regulated entities build a roadmap and strategy to produce their wind-down plans.

Supported on numerous projects relating to stressed/distressed companies. This includes performing independent business reviews, as requested by lenders, as well as working on an administration.