It is always interesting to learn from those that have gone before. In 2015, when planning for the introduction of new Senior Managers Regime (SM&CR), most banks at the time focused their efforts almost entirely on their plans for the Senior Manager Regime (SMR) aspect and tackled the challenges of Certification separately.
However, looking back on their experience of implementing SM&CR, the majority of banks we have spoken with since that time wish they had invested more effort in planning their Certification Regime (CR) up front and at the same time as planning out their approach for the Senior Managers. Feedback from the banks suggest that tackling all the aspects of the regime at the same time would have delivered more efficient processes, a far more consistent approach to managing workflows and records throughout the business and alleviate the risk of inconsistencies in managing different populations and the indefiniteness of unreliable records.
So the message is clear, whilst of course you must carefully plan your SMR arrangements do not ‘short change’ your plans for your CR and do what you can to plan out your end to end processes and procedures.
There are three key steps that, if well thought through, will lay the foundations for successful implementation of your Certification Regime;
1. Decide which roles will fall under your Certification Regime - Sounds simple, but most firms find this decision far more difficult than they originally thought
2. Decide which Significant Harm Function or Functions (SHF) apply to each role - Again, sounds simple, but matching roles to the most suitable SHF from the regulator’s list is not easy
3. Decide how you are going to measure annual competence - Invariably, some processes currently in use in the company will be used but whether they are sufficient to meet the needs of the new rules requires thought. Click HERE to read the 'Statement of Good Practice' guidance on assessing F&P published by the Banking Standards Board; an invaluable set of principles that apply to every firm now effected by the new regime.
For the best insight on what you should be considering when planning your processes and procedures, click on the link below to download your free Certification Briefing Paper written by Julie Pardy, Worksmart’s Director Of Regulation & Market Engagement. Julie is one of the industries most experienced experts in all things SM&CR. This is the first in a two-part series and focuses on:
- Getting Started - what does a firms Certification process need to look like
- Fit & Proper tests - Key components and how to validate F&P
- Honesty Integrity and Reputation - your commitments and how to manage the requirements.
- Expert commentary and answers to key questions about the new regime.
AND COMING SOON : A second blog on this same theme focuses on the remaining components that make up certification, those being: Competence and Regulatory References, plus some practical guidance on the care required when providing references. To be published shortly...