• 25 Sep

    New SMRComply v5.0 release

    Our latest version 5 is now available and offers major upgrades, improved functionality and features you will definitely want to see!

    Click here for further information.

    HRComply Version 5 Features and Upgrading

    By Neil Herbert Uncategorized
  • 24 Jul

    T-C News July 2018

    The SM&CR and the Consumer Credit Sector

    Firms have had some considerable time now to digest the FCA’s proposals to extend the Senior Managers & Certification Regime (SM&CR) to all regulated firms – although as everyone will be acutely aware – we still don’t have a confirmed timeline on this! In my experience the proposals present specific and bigger challenges to the consumer credit industry compared to other sectors. Why? Well firstly – consumer credit firms are relative newcomers to FCA regulation (just over three years). As a result – their governance arrangements may well not be as well tried and tested as firms which have been regulated by the FCA for much longer.


    By Neil Herbert Articles News
  • 18 Apr

    T-C News – April 2018

    Focusing only on delivery deadlines for FCA regulatory requirements could be a costly strategy

    The FCA still haven’t confirmed timelines for SMCR/Accountability 2 for all Financial Services Sector firms (we now know insurers will be at the end of the year) and whilst that remains the case it seems that many firms – that will come in scope – are deferring plans and decisions in terms of their response to it.

    As we know the actual dates for Accountability 2 will depend on the Treasury finding space to push the required legislation through and – as we also know – the legislative timetable and indeed HM Treasury are rather busy right now – with all things Brexit!  Add to this the focus of many firms on MiFID II and GDPR (and in the Insurance sector IDD) and it is understandable that there may be slippage in focus on SMCR/Accountability 2.  However, the requirements of all these significant slabs of regulation/legislation share many common requirements and – in particular – T&C implications and obligations.  Given the more urgent deliveries around the first two it is worth exploring what these are.


    By Neil Herbert Articles News
  • 02 Nov

    Compliance Matters – 26 October 2017

    The art of self-defence: how to protect yourself from the SMR

    The new Senior Managers and Certification Regime is not just intended to encourage high-ranking executives to be responsible for their actions; employees also need to consider how to best protect their own interests.

    Not all aspects of the SM&CR have come into force yet, but we now know that in 2018 the regime will be rolled out across the entire financial services sector, affecting up to 46,000 firms.  The profound changes it brings will include prescribed governance structures, recordkeeping, registration and managerial requirements. READ MORE

    By Neil Herbert Articles News
  • 26 Oct

    T-C News online – 20 September 2017

    SM&CR – Accountability 2 – the costs of an “appropriate” response

    So the proposed details of the Accountability 2 regime are out there and firms now at least have some answers regarding proportionality and the levels of requirement that will apply to them.  As before the Consultation Papers’ publication – many firms still appear to be focusing on the ‘least case scenario’ i.e. what is the least they can do to get away with it.

    This has to be a worrying attitude and one that just doesn’t cut it with the cultural principles changes that the FCA is looking to achieve across the industry.  Instead firms should be focusing on what does good look like and applying the highest practical standards that they can achieve based on budgets and resources available. READ MORE

    By Neil Herbert Articles News
  • 03 Jul

    Financial Adviser – 15 June 2017

    Getting clear about disclosure

    The FCA recently conducted a suitability review of 656 IFAs and intermediary firms. The good news is that overall it found firms were indeed largely providing suitable advice. There were some variations with restricted firms and network members generally doing better than independent directly authorised firms.

    It did, however, express general disappointment at the levels of disclosure being provided – with 69 per cent of network members offering acceptable levels while, again, the directly authorised firms performed worse – with only 46 per cent meeting expected standards.


    By Neil Herbert Articles News
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