Boardroom Readiness for Twin Peaks: Twelve Months to Build What the New Regime Will Require

The shape of the work

The boardroom readiness work for Twin Peaks divides into five categories. Each category contains several sub-streams. The categories are governance, supervisory engagement, control functions, management information, and people. They are interlocking rather than sequential. A board that prioritises governance and defers supervisory engagement will discover during the first post-cutover supervisory cycle that the governance reforms produced no visible operational change. A board that prioritises supervisory engagement and defers control function maturation will discover that the new regulator is asking questions the institution cannot answer with the data it has. A credible boardroom readiness programme works on all five categories in parallel.

The total scope of the work is substantial but not extraordinary. The international evidence base, drawn from boards that worked through equivalent transitions in Australia, the UK, the Netherlands, New Zealand and South Africa, suggests that an institution that begins systematic readiness work twelve months before the cutover is broadly on schedule. An institution that begins six months before is behind. An institution that begins three months before is in remediation rather than readiness. The Caribbean cutover is now within twelve months. The window in which proactive readiness is still possible is closing.

This article walks through each of the five categories in turn, sets out the sub-streams within each, and identifies the governance arrangements, decisions and resourcing implications that each category brings. The intention is not to provide a complete project plan — the specific work required varies by institution size, sector and complexity — but to give boards a structured map against which to assess where their own readiness work stands.

Category 1: Governance

Governance readiness is the foundation. Three sub-streams require particular attention.

The first is board composition and committee structure. Under the new regime, supervisory engagement with the conduct FSC and the prudential BOJ will draw heavily on the institution’s audit committee, risk committee, and any conduct or customer outcomes committee the board has established. The international evidence is clear that boards which operate well-resourced, well-composed and well-disciplined committees produce supervisory engagement that is materially smoother than boards that operate combined or lightly-staffed committees. Boards should examine whether their current committee structure provides sufficient specialist focus on conduct, on customer outcomes, on risk and on audit, and whether each committee has the independent membership, the technical expertise and the operating cadence that the new supervisory expectations will assume.

The second is the documented allocation of senior management responsibilities. Whether or not the legislation includes SMCR-equivalent provisions, the supervisory expectation that boards know who is accountable for what — by name, in writing, with evidence of oversight — is universal across mature regulatory regimes. Boards should commission, if they have not already, a comprehensive documented allocation of responsibilities covering every regulated activity, every material risk category and every customer outcome dimension. The documentation should be structured to support both internal accountability and external supervisory engagement, with named senior individuals and articulated reporting lines.

The third is board reporting quality. The information packages that boards receive on conduct matters, risk matters, capital matters and customer outcomes matters need to be designed for the supervisory paradigm the new regime will operate. Outcomes-based regulation requires outcomes-based board reporting. Disclosure-based reporting that lists what the institution disclosed, how many customers were served, and what complaints were received is materially less useful than outcomes-based reporting that shows what customer outcomes were actually achieved, by segment, over time, with comparison to internal targets and external benchmarks. Boards should review their current reporting suite against the standard of reporting that mature jurisdictions now expect.

Category 2: Supervisory engagement

Supervisory engagement readiness is the operational dimension that institutions most often underestimate. Three sub-streams matter most.

The first is the institution’s regulatory engagement function. Most Caribbean financial institutions today operate a regulatory engagement function sized for engagement with one regulator — the existing FSC. Under Twin Peaks, prudentially-regulated institutions will engage with the BOJ on prudential matters, with the new FSC on conduct matters, and in some cases with the JSE on SRO matters. Each of the three supervisors will have its own examination cycle, its own reporting expectations, and its own enforcement powers. The regulatory engagement function needs to be reorganised to operate effectively across the three relationships, with the senior leadership coordination, internal escalation pathways and supervisory communications protocols that triple supervision requires.

The second is the supervisory data flow capability. The new conduct regulator, post-cutover, will issue supervisory data requests at granularities and frequencies that materially exceed those of the existing FSC. Customer outcomes data, complaints data, vulnerable customer data, product performance data, capital adequacy data, and operational risk data will all need to be producible on supervisory request within the timelines the regulator sets. Building this capability under enforcement pressure is materially more expensive than building it before the supervisory request arrives. The data infrastructure, the data quality controls, and the production processes should all be operational well before the cutover.

The third is the engagement strategy itself. Institutions that have engaged with previous Caribbean regulatory transitions report that the institutions which built constructive, transparent supervisory relationships in the first months of the new regime were treated more favourably than those which adopted defensive engagement strategies. The institutional credibility of the new conduct FSC will build over approximately five years of operating experience. Institutions that engage constructively from Day One will benefit from that institutional development. Institutions that wait for the regulator to prove itself will find that the relationship is shaped by the engagement history of the preceding period.

Triple supervision changes how regulatory engagement is resourced. Internal escalation pathways, supervisory communications protocols and senior management coordination need to anticipate the operational complexity that three supervisors with three examination cycles produces.

Category 3: Control functions

Control function maturity is the technical dimension of boardroom readiness. Four control functions need particular attention.

The first is risk management. The new prudential regime will operate with materially upgraded risk management expectations including ICAAP-equivalent capital adequacy assessment, comprehensive operational risk frameworks, and integrated stress testing. The institution’s risk function needs to be sized, resourced and structured to operate to international risk management standards. Boards should assess whether the current risk function has the headcount, the technical capability, the data infrastructure and the governance access to operate at the standard the new regime will require.

The second is compliance. The shift from disclosure-based to outcomes-based regulation reorganises the compliance function’s work. Under the legacy framework, compliance was substantially about ensuring that the institution disclosed what it was required to disclose. Under the new framework, compliance is substantially about ensuring that the institution achieves the customer outcomes the conduct regulator expects. The compliance function needs to be restructured around customer outcomes, fair value assessment, vulnerable customer treatment, and complaints data analysis rather than around disclosure compliance alone.

The third is internal audit. The post-cutover supervisory regime will draw on internal audit work materially more than the legacy regime. The conduct regulator will look to internal audit for assurance on customer outcomes frameworks, on complaints handling, on vulnerable customer programmes, and on conduct risk frameworks. The prudential regulator will look to internal audit for assurance on capital adequacy frameworks, on credit risk frameworks, on operational risk frameworks, and on stress testing. Internal audit’s coverage plan, technical capability, reporting quality and access to senior management need to be at the standard the dual supervisory regime expects.

The fourth is the conduct or customer outcomes function. Most Caribbean financial institutions today do not operate a dedicated conduct or customer outcomes function — these matters are typically distributed across compliance, customer service, complaints handling, marketing and operations. Under outcomes-based regulation, a dedicated function with end-to-end accountability for product governance, fair value assessment, customer communications, customer service standards and customer outcomes is increasingly the international norm. Boards should consider whether their institution would benefit from establishing such a function ahead of the cutover.

Category 4: Management information

Management information readiness is the operational test of every boardroom readiness programme. The board’s ability to receive timely, accurate, granular information on the dimensions the new regime will supervise is the practical condition for everything else in the readiness programme. Five management information streams matter most.

The first is customer outcomes data. The supervisory paradigm under the new regime turns on customer outcomes — by product, by segment, by vulnerability category, over time. The board’s reporting on customer outcomes should be at the standard the regulator will expect. The data infrastructure to produce this reporting takes time to build, and the analytical layer that translates raw customer outcomes data into board-level insight is itself a specialist capability that needs to be developed.

The second is complaints data. Complaints volumes, resolution times, root causes, repeat issues, vulnerable customer indicators, and trend lines should be reported to the board at a cadence and granularity that supports both internal management and external supervisory engagement. The legacy approach of treating complaints as a customer service operational matter has been overtaken by the international supervisory expectation that complaints data is a strategic management information system.

The third is risk data. The board’s risk reporting should cover credit risk, market risk, liquidity risk, operational risk, conduct risk, and emerging risks at the standard the new prudential regulator will expect. Stress testing scenarios, capital adequacy projections, and risk appetite framework reporting should be at the standard mature jurisdictions now expect.

The fourth is capital and liquidity reporting. Under the new prudential regime, capital adequacy reporting will be more detailed, more frequent and more publicly disclosed than under the legacy regime. The board should receive capital and liquidity reporting at the standard that supports both internal capital management and external prudential supervision.

The fifth is management information governance itself. The processes by which the board receives information, challenges it, and acts on it are themselves a supervisory consideration. Boards that operate a tight, disciplined, action-oriented information governance routine produce supervisory engagement that is materially better than boards that operate looser arrangements.

The board’s ability to receive timely, accurate, granular information on the dimensions the new regime will supervise is the practical condition for everything else in the readiness programme.

Category 5: People

People readiness is the often-overlooked dimension of boardroom readiness. Three sub-streams matter.

The first is senior management capability. The senior management team that has operated under the legacy supervisory regime may or may not have the capability profile that the new regime will require. The shift from disclosure-based to outcomes-based regulation, the introduction of triple supervision for some institutions, and the substantively higher penalty calibration all change the capability profile that senior management roles require. Boards should assess whether the current senior management team has the technical capability, the regulatory engagement experience, and the strategic capability to operate effectively under the new regime.

The second is specialist headcount. The control functions, the regulatory engagement function, and the customer outcomes function will all require specialist capabilities that may not currently exist within the institution at the depth the new regime will require. Boards should ensure that the people-readiness work includes deliberate recruitment and development planning for the specialist roles that the new regime will require.

The third is board capability itself. The directors who will oversee the institution under the new regime need to have access to the technical understanding, the supervisory engagement experience, and the strategic context that the new regime will assume. Board education programmes, briefings from external regulatory experts, and structured engagement with the supervisory expectations of mature jurisdictions are all part of the people-readiness work for the board itself.

The sequencing challenge

The five categories of readiness work are interlocking rather than sequential, but the underlying components within each category have natural sequencing. Documented allocation of senior management responsibilities should precede the supervisory engagement strategy work. Customer outcomes data infrastructure should precede the customer outcomes board reporting work. Specialist recruitment should precede the control function structural reorganisation. Each component takes time to deliver, and the time required compounds when components depend on each other.

A board that begins systematic readiness work twelve months before the cutover can sequence the components in the order that international experience suggests works best. A board that begins six months before is forced to compress the sequence, and the compression typically produces sub-optimal results. A board that begins three months before is operating in catch-up mode rather than readiness mode.

The Caribbean cutover is now within twelve months. The institutions that have begun systematic readiness work are well-placed. The institutions that have not yet begun should treat 2026 as the year to commission the work, with the structured sequence above as the framework. The cost of doing the work now is materially less than the cost of doing it under enforcement pressure later.

What boards should do this quarter

For boards that are still at the planning stage of readiness work, three actions in particular have a strong return on investment in the next ninety days.

The first is to commission an independent diagnostic of the institution’s readiness across the five categories. The diagnostic should compare the institution’s current arrangements against the international benchmarks the new regime will draw on, identify the most material gaps, and produce a prioritised remediation roadmap with resource estimates and timeline implications. The diagnostic itself takes approximately six weeks for a mid-sized institution and produces the structured input that the board’s readiness governance requires.

The second is to establish a board-level readiness governance function. Whether this is a sub-committee of an existing committee, a temporary readiness committee with a defined sunset date, or an executive-led programme reporting to the board, the governance arrangement should ensure that readiness work has board-level visibility, board-level accountability, and the senior management coordination that cross-functional readiness work requires.

The third is to commission specialist external support where the institution’s internal capabilities are insufficient. The readiness work draws on specialist regulatory advisory experience, conduct framework expertise, capital and risk management capability, and supervisory engagement experience that few Caribbean institutions hold internally at the depth required. External support is not a substitute for internal capability, but the right external support accelerates the internal capability build and avoids the false starts that internally-led readiness work without specialist input often produces.

The wider preparation

The five categories of boardroom readiness above focus on what the institution itself needs to do. The wider preparation for Twin Peaks involves three additional dimensions that boards should also consider.

The first is industry engagement. The Caribbean financial sector industry associations, the JSE, and the wider professional services community are all engaged in their own readiness work. Boards that participate actively in industry engagement — through their CEOs, their compliance leadership, their risk leadership — benefit from the collective intelligence the engagement produces and contribute to the industry-wide readiness that the new regime ultimately depends on. Active industry engagement is itself part of credible boardroom readiness.

The second is policy engagement. The legislative drafting work currently underway is responsive to industry input through the established consultation channels. Boards that engage substantively with the consultation process — through written submissions, through industry association coordination, through direct engagement with the Ministry of Finance, the BOJ and the FSC — contribute to the quality of the legislation that ultimately emerges. The institutions that engage thoughtfully tend to produce input that the drafters take seriously. The institutions that engage only after the legislation is finalised find that their preferences arrive too late to be incorporated.

The third is regional engagement. The Caribbean financial sector operates across multiple jurisdictions, and the Jamaican Twin Peaks transition has implications for institutions and counterparties throughout CARICOM. Boards of institutions with regional operations should ensure that the readiness work covers cross-border supervisory cooperation, regional regulatory consistency questions, and operational implications of differential regulatory development across the region. The institutions that engage thoughtfully with the regional dimension will be better positioned than those that treat the Jamaican transition as a domestic matter alone.

Closing this article, and what comes next

Boardroom readiness for Twin Peaks is the operational dimension of everything the previous ten articles in this series have analysed. The international evidence base, the structural diagnostic of the JSE, the IOSCO Principles compliance gap, the investor protection architecture, the legislative reform package — all of this analysis ultimately translates into the work that boards of Caribbean financial institutions must do over the next twelve months. The work is substantive, the time available is finite, and the cost of doing the work proactively is materially less than the cost of doing it under enforcement pressure after the cutover.

Article 12 closes the series with the longer view. What does a Caribbean capital market worthy of international capital look like over the decade following the cutover. What can the Twin Peaks transition position the Caribbean to achieve. The closing article moves from the immediate operational concerns of boardroom readiness to the strategic horizon — the case for what the Caribbean financial sector can become if the work of the next twelve months is done well.

 

PARTNER WITH DAWGEN GLOBAL From Analysis to Operational Readiness The boardroom readiness work for Twin Peaks is substantive, and the window in which proactive readiness is still possible is finite. The institutions that begin systematic readiness work now will operate smoothly under the new regime. The institutions that wait will be doing the work under enforcement pressure. Dawgen Global brings audit, assurance, capital market regulatory and conduct framework expertise to translate the analysis of the previous ten articles into the operational readiness programmes that boards of Caribbean financial institutions need to commission — Big Firm capabilities, with Caribbean understanding. Six advisory engagements designed for this moment: ▸  Twin Peaks Readiness Diagnostic — independent benchmarking of an institution’s readiness across governance, supervisory engagement, control functions, management information and people, with prioritised remediation roadmap aligned to the cutover timeline. ▸  Senior Management Responsibilities Documentation — comprehensive documented allocation of regulatory responsibilities covering every regulated activity, material risk category and customer outcome dimension, structured for both internal accountability and external supervisory engagement. ▸  Triple-Supervisor Operating Model Design — internal regulatory engagement frameworks designed to operate under prudential supervision, conduct supervision and SRO supervision concurrently, including escalation pathways, supervisory communications protocols and senior management coordination. ▸  Board Reporting Suite Modernisation — review and redesign of board information packages on conduct, risk, capital and customer outcomes against the standard the new regime will expect. ▸  Customer Outcomes Data Infrastructure Programme — design and implementation of supervisory-grade reporting on customer outcomes by product, segment, vulnerability category and time, with the analytical layer that translates raw data into board-level insight. ▸  Specialist Recruitment & Capability Development — structured recruitment and development planning for the specialist roles that the new regime will require across risk management, compliance, internal audit, conduct and regulatory engagement functions. Begin the conversation today. Email: [email protected]

 

COMING NEXT IN THIS SERIES

Article 12  —  After Twin Peaks: A Caribbean Capital Market Worthy of International Capital

The closing article in this series moves from the immediate operational concerns of boardroom readiness to the strategic horizon. What does a Caribbean capital market worthy of international capital look like over the decade following the cutover. What can the Twin Peaks transition position the Caribbean to achieve. The series closes with the case for what the Caribbean financial sector can become if the work of the next twelve months is done well — and what is at stake if it is not.

ABOUT THE AUTHOR

Dr. Dawkins Brown is the Executive Chairman and Founder of Dawgen Global, an independent, integrated multidisciplinary professional services firm headquartered in New Kingston, Jamaica, operating across more than fifteen Caribbean territories. With Big Four heritage and over twenty-three years of professional experience, Dr. Brown writes regularly on Caribbean financial regulation, capital markets, governance and strategy through the LinkedIn newsletter Caribbean Boardroom Perspectives.

About Dawgen Global