This blog seeks to help you plan your project for the implementation of the Senior Managers and Certification Regime.
Training & Competence (T&C) has been a regulatory requirement of the Financial Conduct Authority (FCA) since the late 1990’s. As such, it doesn’t grab the headlines the way more recent regulation, such as MIFID II Knowledge and Competence, Insurance Distribution Directive and Senior Managers & Certification Regime have. However, these newer regimes all have the same underlying theme, that being key staff have, and evidence, the knowledge and competence necessary for them to fulfil their jobs effectively. As a result, activities like regular performance reviews, ‘on the job’ observations, programmes of continuing professional development (CPD) and robust record keeping supported by effective monitoring have never been more relevant. Therefore, whilst not necessarily grabbing the headlines, never have the principles and underlying activities of T&C been more relevant.
This Blog seeks to introduce you to planning for the implementation of the Senior Managers and Certification Regime (SM&CR) and is a continuation of the last Blog where we looked at this subject with regard to Insurers. The purpose of this blog is to discuss the timings for implementation that affect Solo Regulated Firms and to give you some tips on preparing for implementation.
Like many projects, the most challenging part of implementing the Senior Manager and Certification Regime (SM&CR) is getting organised and ensuring the project is set up to ensure success. Without this, the chances of a flawed and ill thought through implementation increase dramatically.
Literature and philosophy is laden with theories and principles that rely on seven pillars. In this blog, I won’t attempt to reconsider the seven pillars of wisdom, life or anything that highbrow, (believe me, it wouldn’t be that insightful a piece!). Instead I will focus on something far more down to earth, but no less important for those given the responsibility of preparing an organisation for the implementation and management of SM&CR and its associated records.
In order to kick start the SMR (Senior Manager Regime) component of your SM&CR (Senior Managers and Certification Regime) implementation, considering these 5 key areas will help set your project off on the right path;
When firms first start planning for the implementation of the new SM&CR regime, they seldom prioritise the ongoing challenge and risks associated with how well systems and processes will support things after it goes live and becomes business as usual. The challenges of managing a consistent approach across the various workflows; the difficulty of joining together what are often disjointed or siloed processes; how to ensure a robust and consistent approach to the related procedures across the firm, and crucially; future-proofing of your systems and processes and maintaining an comprehensive and accessible audit trail.
When applying the new Senior Manager & Certification Regime (SM&CR) to your organisation, the regulator will expect more than just a Management Responsibilities Map (MRM) summarising the allocation of Senior Manager Functions (SMFs) and Prescribed Responsibilities (PR). The regulator will expect these things set within the context of a firm's wider governance arrangements.