Lighthouse Financial Services Company — Who does what across 20 governance and 13 delivery activities, using a notation extended by two characters that standard RACI does not have. Status as at 16 October 2026.
1. Why Standard RACI Breaks Here
Standard RACI assumes a decision structure in which somebody approves and everybody else feeds in. That assumption holds on most programs, which is why the notation has survived unchanged for decades. It does not hold here.
The alternative to extending the notation is to flatten it — to write a matrix that shows one accountable person per activity and quietly hand the Chair both the evidence job and the decision job. That is exactly the concentration this governance model exists to prevent, so the notation gives way instead of the governance.
2. Notation
| Meaning | Definition | |
|---|---|---|
| R | Responsible | Does the work. |
| A | Accountable | Answerable for the outcome of the activity. One per row, except where noted at §4. |
| C | Consulted | Two-way input before the activity completes. |
| I | Informed | One-way notification after the fact. |
| V | Vote | Casts a binding vote. Not standard RACI. Added because five executives decide gate outcomes and “Consulted” would misdescribe them. |
| F | Facilitate | Answerable for the integrity of the evidence, without a vote (Decision D-11). Also not standard RACI. |
A/F appears once, at evidence certification, and is the single cell where the Chair is both answerable for an activity and facilitating the body that consumes it. It is called out rather than smoothed over.
Roles
| Code | Role |
|---|---|
| Chair | C. Tyrrell — NPD Program Manager |
| CPO | G. Marchetti — Chief Product Officer, Sponsor |
| CA | N. Adeyemi — Chief Actuary |
| GC | B. Lindqvist — General Counsel & CCO |
| HoD | R. Castellanos — Head of Distribution |
| CFO | J. Whitmore — Chief Financial Officer |
| CRO | D. Pemberton — Chief Risk Officer (observer) |
| PMO | K. Iyer — PMO Lead / Gate Secretariat |
3. Tier 1 — Governance Matrix
The nine seats that decide. This is the tier where V and F exist.
| Activity | Chair | CPO | CA | GC | HoD | CFO | CRO | PMO |
|---|---|---|---|---|---|---|---|---|
| Gate operations | ||||||||
| Assemble the gate package | A | I | C | C | C | C | I | R |
| Certify that tabled evidence meets the recorded standard | A/F | I | C | C | I | I | I | R |
| Score should-meet criteria | F | V | V | V | V | V | C | R |
| Certify must-meet criteria in own function | F | I | A | A | A | A | C | R |
| Decide the gate outcome | F | V | V | V | V | V | C | I |
| Record dissent in the gate package | A | C | C | C | C | C | C | R |
| Issue gate conditions | R | V | V | V | V | V | C | R |
| Verify and close a condition | A | I | I | I | I | I | I | R |
| Authorize a contingency draw | R | V | V | V | V | V | C | I |
| Issue a vendor release notice | A | I | I | I | I | I | I | R |
| Program management | ||||||||
| Maintain the program budget and tranche ledger | A | I | I | I | I | C | I | C |
| Maintain the RAIDD register | A | I | I | I | I | I | C | R |
| Publish the dashboard and weekly status | A | I | I | I | I | I | I | R |
| Resource the program from functional teams | C | A | C | C | C | C | I | I |
| Product & regulatory | ||||||||
| Set and sign the pricing basis | I | C | A | I | I | C | C | I |
| Draft and clear contract forms | I | I | C | A | I | I | I | I |
| Submit and manage regulatory filings | I | I | C | A | I | I | I | I |
| Establish hedging capability | I | I | C | I | I | A | C | I |
| Secure written channel commitments | C | C | I | I | A | I | I | I |
| Deliver suitability and best-interest training | I | I | I | A | C | I | I | I |
4. Tier 2 — Delivery Matrix, by Individual
The governance matrix above names seats. This one names people — every delivery owner is a specific individual from the 90-person roster, validated at generation time, and the generator refuses to write if any of them is not a real member of the program.
| Delivery activity | DF | SR | TB | MD | VS | EK | PH | AN | LM | HK | BT | FO |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Set and sign the pricing basis | C | A | C | — | — | — | — | — | — | — | I | — |
| Produce the actuarial memorandum and rate support | — | A | R | — | — | — | C | — | — | — | — | — |
| Draft and clear contract forms | C | — | — | — | — | — | R | A | — | — | — | — |
| Prepare and lodge regulatory filings | I | — | — | — | — | — | A | R | — | — | — | — |
| Configure the administration platform | — | — | — | — | A | — | — | — | C | — | — | C |
| Build and validate the illustration engine | — | C | — | — | C | A | — | C | — | — | — | — |
| Design and execute the hedging program | — | — | C | A | — | — | — | — | — | — | C | — |
| Structure the reinsurance treaty | — | — | A | C | — | — | — | C | — | — | C | — |
| Build new business and servicing processes | — | — | — | — | R | — | — | — | A | — | — | C |
| Secure written channel commitments | C | — | — | — | — | — | — | — | — | A | — | — |
| Deliver advisor training and appointment | I | — | — | — | — | — | — | A | — | R | — | — |
| Maintain the program budget and tranche ledger | — | — | — | — | — | — | — | — | — | — | A | C |
| Produce program reporting and the dashboard | — | — | — | — | I | — | — | — | I | — | C | A |
Who these people are
| Code | Name | Role | Team |
|---|---|---|---|
| DF | D. Falkner | VP Product Development | Product Management & Design |
| SR | S. Ravichandran | Lead Pricing Actuary, FSA | Actuarial - Pricing & Product Development |
| TB | T. Brennan | Valuation Actuary, FSA | Actuarial - Valuation & Financial Reporting |
| MD | M. Delacroix | Director, ALM & Hedging | Investments - ALM & Hedging |
| VS | V. Sandoval | Platform Delivery Lead | IT - Annuity Administration Platform |
| EK | E. Kowalczyk | Illustration Systems Lead | IT - Illustration & Quoting |
| PH | P. Hollingsworth | Manager, Product Filing | Regulatory Filing & Contract Forms |
| AN | A. Nkemelu | Senior Counsel - Product | Legal & Compliance |
| LM | L. Marchand | Director, Annuity Operations | Operations - New Business & Policyholder Services |
| HK | H. Kirkpatrick | National Sales Manager | Distribution & Wholesaling |
| BT | B. Trombley | Program Finance Manager | Finance & Treasury |
| FO | F. Osunde | Data Lead | Data, Reporting & Analytics |
5. Where Accountability Splits
Three rows carry a V across five columns and an F in the Chair's: scoring the criteria, deciding the outcome, and issuing conditions. Those are the rows where accountability splits, and the split is deliberate.
| Accountable for | Who | Meaning |
|---|---|---|
| The evidence being sound | Chair | That what was tabled meets the standard recorded at issue — not that it supports any particular conclusion. |
| The decision being right | The five voting seats | That the conclusion drawn from that evidence is the correct one for the carrier. |
6. The Observer Problem
The Chief Risk Officer attends every gate, sees every package, and does not vote. Standard RACI offers only C or I, and neither fits well: I understates a role with a standing seat and full visibility, while C overstates it by implying the program must solicit and address input before proceeding.
C is used, with this paragraph as the qualification. The CRO's contribution is observational rather than transactional — the value of the seat is that enterprise risk sees the decision being made, not that the decision waits on it. Recording that as I would make the seat look ceremonial, which is the misreading the role exists to avoid.
7. The Conflict Rule
The matrix cannot show this, because it is a rule about a specific gate rather than a standing allocation. It is recorded here because a reader who takes the V column literally would count five votes at Gate 2 and find four.
8. What the Matrix Reveals
- The Chair is Accountable on 8 of 20 activities and votes on none of them. That ratio is the governance model in a single number: heavy operational accountability, zero decision authority.
- Every product and regulatory activity is Accountable to a functional executive, not to the program. Pricing to the Chief Actuary, forms and filings to the GC, hedging to the CFO, channel commitments to the Head of Distribution. The program coordinates work it does not own, which is what makes the matrixed org chart necessary rather than merely convenient.
- Four executives are both Accountable for work and voting on the program that consumes it. The Chief Actuary signs the pricing basis and votes on whether the business case built from it should proceed. That is unavoidable in a functional carrier and is why the abstention rule at §6 exists at all — it handles the sharpest instance, not the general condition.
- Resourcing is Accountable to the sponsor, not the Chair. The program cannot staff itself; it borrows from functions. Assumption A-08 — that no competing internal launch draws the same actuarial and IT people in 2027 — is exposed precisely here, and the matrix shows why: nobody in the Chair column can hold anyone.
Maintained by C. Tyrrell, NPD Program Manager and Chair of the Gate Review Board. Related: Stage-Gate Governance Model §4, §6.3 · Org Chart · Gate Conditions Register · Program Charter §8–9.