For solo-regulated firms, the SM&CR implementation date has arrived.  We’re proud to have successfully prepared some of the UK’s best known financial brands for this impending regime.  What we have also discovered is that surprisingly, many firms are still not ready and there’s a surprising reason as to why. 

CONCON 4.2 SC1: "You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively"

"You can delegate authority but you can not delegate responsibility"

Former U.S. Senator Byron Dorgan

We ran our first ever webinar on 30^th September and this is what we learnt.

The webinar, ‘SM&CR the final countdown – 50 working days to go’, was co-hosted with TISA and focused on the major outstanding actions that firms should be focusing on ahead of ‘Day One’ on December 9^th. 

KNOWLEDGE – “Facts, information and skills acquired through experience or education.  The theoretical or practical understanding of a subject”

COMPETENCE - “The ability to do something successfully or efficiently”

‘Final call for SM&CR’ – Are you sure your preparations are taking you in the right direction?

Read “Rising to the challenge of the Certification Regime”, by Julie Pardy to help ensure your SM&CR journey ends up at the right destination!

45 individuals interviewed across 15 Banking institutions

In what has been described by the FCA as an SM&CR “Stocktaking Report” in the Banking Sector, the most recent FCA publication gives us an insight into what they found across the sector.

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. 

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. 

Appropriate and effective competence frameworks have been a regulatory requirement in Financial Services since the early 1990’s. The concept of T&C was introduced back in the early 90’s by LAUTRO and then refined by the PIA and FSA over the late 1990’s and 2000’s. More recently however, T&C has taken a bit of back seat to more recent regulation, such as MIFID II Knowledge and Competence requirements, the Insurance Distribution Directive and the Senior Managers & Certification Regime. However, these newer regimes all have the same underlying theme, and that is to ensure that organisations have structured and effective processes so that employees have the knowledge and competence necessary for them to fulfil their roles effectively. Therefore, whilst not necessarily grabbing the headlines, the concept of structured and effective T&C regimes remain at the forefront of our regulator’s approach to managing employee competence.

This series of three blogs is designed to help you review the fitness of your T&C or wider competence management arrangements. We aim to challenge you to consider whether your current approach is fit for purpose.