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SM&CR Implementation Tasks                      Part Six - Key Considerations

Posted by Julie Pardy on March 11, 2019
Julie Pardy
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Questions & Considerations

This blog seeks to continue to help you plan your project for the implementation of the Senior Managers and Certification Regime.

Often, people say to us that they don’t feel that they need to take any action now as the regime doesn’t start for a while and then there is another year from the start date to complete lots of other tasks. However, if you ask the Banking community, what would they would do differently, if they had to do this again? They would say they would take action far earlier.

Now, it would have been difficult for the Banking Community to do this as they had some quite short timelines from when the regulatory change was announced to achieving the deadlines for commencement. That said, there are some things that you can do now that will most definitely make your life easier as you get closer to your first regulatory deadline. Our earlier blogs concentrated on HR Tasks, Employment Tasks, Training Tasks, Governance Tasks and Process Management Tasks.

Now we are going to look at some key considerations, things we have learned along the way that we think are important questions to ask yourselves as you embark on your own implementation.

Blog 11 Slide 1

SM&CR touches so many parts of a business that this is actually a really big regulatory change. An approach that has worked well for some of our clients would be to think about what do you want SM&CR to give your business? What can it do for you? Think about what output you need to ensure that it happens.

Every organisation knows that they have a process somewhere in the business that doesn’t quite work properly. It might be slightly broken, there might be lots of ‘work arounds’ that don’t sit quite right. Think about the opportunity that SMCR gives you to make those improvements. So, if you are not happy with your performance appraisal system, it’s not working, make changes to improve it.

Your T&C regime might be handled manually on excel spreadsheets or paper folders making it difficult to identify people’s competencies and capabilities. Think about how you might be able to systemise that in line with SM&CR to make things work more effectively for you.

Finally, this is a long project. It will take you between 6-12 months, possibly more, to implement this effectively. Think about the measures you will put in place to track your project, track the people working on your project and hit some key milestones as you go along the way.

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Five key questions you need to answer for yourself in readiness for the SM&CR regulation:

  • Do you understand the full implications of the new regime?
  • Have you considered the impact of the regime on your business and your staff?
  • Do you understand the impact of managing the regime beyond the initial implementation?
  • Does your organisation appreciate the value of future proofing your systems and processes?
  • Are  you confident in your existing systems and processes to deliver SM&CR compliance?

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