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SM&CR Project  tasks & useful tips          Part Three - Who does what?

Posted by Julie Pardy on March 11, 2019
Julie Pardy
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This blog seeks to help you plan your project for the implementation of the Senior Managers and Certification Regime.

Blog 3 Slide B

The Worksmart Team have a great amount of experience in implementing SM&CR in the Banking world. We’ve been working with banks since before the regime came into being around Summer 2015 and so we have more than 3 years’ experience of implementing and working with firms.

Who does what?

One of the most common questions we are asked is, ‘Who Does What within an SM&CR Project?’ and typically, ‘What areas of the business are represented?’.

Blog 3 Slide 6

You will see from the slide that we have identified a number of key departments within a business that typically are involved in any SM&CR implementation. This is not to say that other departments won’t be involved as they probably will be, but these particular departments are worthy of comment.

HR – is the biggest component part on this diagram for a reason. The reason being that this is a people based regulatory change project and, as a result, a lot of the processes will be owned and/or managed by HR.  This typically means that HR team members make up a large part of the project team to help drive the people agenda.

Compliance – your compliance colleagues need to be part of this from Day 1. Their support is needed in terms of guidance and advice on the regulations, the regulatory change and how that will impact your existing systems, processes and people.

Legal & Risk – there are some employment law implications here as a result of the changes of this regime. It’s likely that people, especially Senior Managers, may want to take legal advice as to their position of holding the accountabilities that will be given to them within the business. From a Risk perspective, there is also consideration around how the project approach is shaping up and from a risk management and risk mitigation perspective whether any of the policies and procedures being considered for SM&CR  are within or outside of current risk tolerance.

Where we have seen project teams that contain representation from all of these areas, these appear to be the strongest and most effective as the project moves through the planning and implementation stages.

Look out for our next Blog, ‘SM&CR-Implementation Tasks Part One – HR Tasks’ coming soon…


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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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