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SMCR: Six Months to Go!

Senior Managers & Certification Regime: Six Months to Go!

17th June 2019

With the SMCR Deadline for solo-regulated firms less than six months away on 9th December 2019, many firms will be in full swing with their preparations for implementation.

However, for those still tentatively toeing the edge and yet to dive in, you’d best think about taking the plunge soon. Lessons learnt from other sectors to which SMCR already applies is that starting late can leave you unprepared, especially if your firm also underestimates the impact this regulation will have upon them.

As has been advised again and again by both the regulator, and by those already under the SMCR regime, the best way to implement SMCR is by embedding the requirements within the culture of the firm - but of course this is no mean feat and will take time.

SMCR: Cultural Change

Embracing the new rules and ensuring that a firm’s culture and governance support the objectives of SMCR will help the firm to enter the new regime with confidence, as well as help support the individuals being asked to be accountable. A review of your business, its structures, reporting lines, policies and practices will all need to be undertaken to ensure that they support the regime and that the right people are in the right roles.

As those familiar with financial services will know, culture and governance has received increasing focus from the Regulator over the last few years - and with SMCR, this regime specifically assigns responsibility to senior managers for promoting a culture of integrity, risk management and compliance. Thus it is vital that Senior Managers are able to understand and support the culture of accountability.

Once you have begun your preparations, perhaps one of the best ways to start embarking upon the cultural shift that is required is to arrange training for the senior managers identified within the firm - covering what the regulation means and what is expected of both the company and of senior managers under it.

Whilst policies and processes can assist in achieving compliance under SMCR, it will be the working practices, culture and governance of those that work at and within the firm, combining individual skills, motivations and values that will help to ensure ongoing compliance with the regime.

Remember,  those that you have initially identified as Senior Managers within your firm may change as you embark upon your preparations for implementation and it is most likely that the population of Senior Managers will alter from now until December. In all cases, you must remember to monitor your populations carefully, particularly if there are role changes in the lead-up to implementation.

And of course, knowing what the regulator is saying on the matter will assist your firm in its preparations, so a rather obvious tip for those preparing for SMCR is to remember to regularly check the FCA website and its supporting material.

SMCR Support Services

Firms must ensure they have the necessary time and resources to implement and manage the requirements of SMCR, and whilst we cannot provide you with more time, we do have the skills and resources to help your firm in making its preparations.

Our team of compliance professionals specialise in providing regulatory support to FCA regulated firms.  Our consultants work with clients to help determine risks in an increasingly complex, ever- changing and evolving regulatory landscape to ensure comprehensive compliance support. So, for any requirement you might have, large or small, we would be happy to help. Just drop us a line and we’ll be happy to call or email you to discuss.

Related Reading:

• SM&CR for Solo-Regulated Firms: Types of Firm
• Starting SM&CR Preparations: What you need to know
• Finalised Guidance: SM&CR Responsiblities - Statements and Mapping
• SMCR Responsiblities: A Comprehensive View & Holistic Approach

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