A crucial output from implementing SMCR is the creation and ongoing maintenance of a Responsibilities Map. In this short article we’ll show you how that’s achieved in Insight SMR in five easy steps by recreating the FCA’s published Map as an example.
TC News April 2017 – Redland Director Carl Redfern writes about how to run an effective RFP process for a technology solution
We’ve recently returned from The Extension of the Senior Managers and Certification Regime conference run by City & Financial and held at the Royal Garden Hotel, London.
The conference was excellent and extremely busy with more than 250 delegates from across numerous sectors of financial services in attendance. Clearly, people are eager to find out more about the extension of SMCR and how it will affect their firms in 2018.
The agenda was certainly packed with one of the highlights being David Blunt’s keynote speech to kick things off. David is the Head of Conduct Specialists at the FCA and he provided some insights into when and how the regime will be extended.
The FCA have been running a pre-consultation process and this will continue into 2017 as they get out and about meeting firms and trade associations. The consultation paper will be issued in Q2 this year.
Implementation of the extended regime (referred to by David as ‘Accountability 2’ during his speech) will be ‘from’ 2018 and is likely to be phased by type of firm.
When SMCR came in for banking in 2016 it applied to approximately 1,000 firms, but with the extension across all FSMA firms, this will grow to 52,000. This is not the sort of thing that can be rolled out ‘over a weekend’.
Ultimately, it is The Treasury who will decide on the actual dates for implementation.
There are steps firms could be taking now to get ready, for example, conducting a self-assessment of their governance arrangements.
Insurers will be subject to SMCR, with the FCA being very keen to avoid having many different regimes for different sectors.
The guiding principles of ‘Accountability 2’ will be clarity, simplicity, consistency and proportionality.
Clearly, there’s a lot more detail to come and we’re all very eager to see the first consultation papers published later this year. That doesn’t mean you need to wait until then to kick things off, take a look at our SM&CR – Are you Ready? post to see what you can be doing now to get ready for the regime.
In 2018 the three tiers of SM&CR (Senior Managers Regime, Certification Regime and Rules of Conduct) will be extended out to all FSMA firms. Since the consultation process has yet to begin, you may be forgiven for answering “Of course I’m not ready!”. Yet there are things you can be doing right now to prepare your firm for the regime.
In this post, we’ll summarise six steps you should be taking now to help ensure a smooth implementation of SM&CR. Then, over the course of the next few months, we’ll take a more in-depth look at each of these steps.
- Gain understanding – familiarise yourself with the current ‘banking’ rules because it will be similar when applied to wider FSMA Firms – Brush up on the details of the existing rules applied to Banking. Don’t be put off by the details, yes, there is complexity down in the weeds but you can gain a good general understanding in a couple of hours.
- Form a working group – Planning for SM&CR will be crucial to successfully embedding the regime within your firm. Common feedback from the Banking world was that Senior Managers felt SMR was being ‘done to them’ rather than ‘done by them’. Don’t make the same mistake, form a working group now and engage key stakeholders early.
- Identify your Senior Manager, Certification and Conduct populations – Identifying a first draft of these populations early will help to assess the scale of any processes and systems that you will need to implement to support the regime.
- Consider Ownership of SM&CR – One of the hottest topics from the Banking sector was around who should own SM&CR. The truth is, there is no right answer to this question. You may want to consider setting up a new department, or it may sit better with HR, or Compliance. What is certainly true is that it will take communication and co-operation across departments to implement the regime successfully.
- Review your existing governance arrangements and documentation – Start to review your existing governance arrangements and how they are documented. Remember that the regulator is not necessarily asking you to change your governance arrangements, but they are asking you to confirm them and accept personal responsibility for them and their effectiveness.
- Plan your solution – How are you going to manage SM&CR? What existing processes and systems do you have in place? Perform a gap analysis vs. the requirements of the regime and plan how you will fill any gaps identified. You should expect change – you will have versions of Maps and Statements before ‘live’ but also ongoing change after implementation.
You should also give serious consideration to attending the upcoming Extension of the Senior Managers and Certification Regime event on 31st January 2017. We’ll be there providing advice and demonstrations of our award-winning SMR solution.
Correctly identifying the nature of a challenge helps us to understand what we need to do and select appropriate strategies to succeed. In this article I will briefly explain what a ‘Super Wicked Problem’ is and why extending SM&CR to all firms falls into this category. I’ll also provide you with some practical advice and tactics for dealing with ‘Super Wicked Problems’.
We’re absolutely delighted to announce that we’ve recently been voted Best Solutions Provider – Senior Managers’ Regime by an independent panel of industry professionals at the recent Compliance Register Platinum Awards 2016. We’re very proud of our SMR solution and it’s fantastic that this has been recognised by the industry.
We had a great time receiving the award at the fantastic event held at the Lancaster London hotel last week.
This year in March, what has become known as the Senior Managers and Certification Regime (SM&CR) came into force for deposit takers in the UK. In the FCA Annual Report for year ending March 2016, they proudly proclaim this regime applies to “over 41,000 people working in over 1000 Firms”.
The recent deadline of 7th March for implementation of the Senior Manager and Certification Regimes (SM&CR) has been subject to a lot of focus in the banking community.
By the deadline Firms subject to the new rules were obliged to submit a Responsibilities Map and draft individual Statements of Responsibilities for all Senior Managers, allocate Senior Manager Functions and prescribed Responsibilities and clearly document the Firm’s governance arrangements.
As a Compliance Officer you will know all about the new Senior Managers Regime, after all it’s been fully implemented now in your firm, or has it?
The SMR came into effect on the 7th March 2016 and in theory all firms should be complying with a combination of the PRA and FCA rules books.
On the 7th March, the new Senior Managers Accountability Regime (Senior Managers Regime or SMR) was implemented. In the run up to implementation and since, NEDs have been engaged to establish what their concerns and observations on SMR compliance are. This article summarises the top five topics raised by NEDs during this survey.