The Senior Managers and Certification Regime (SM&CR) for banks and PRA-designated firms came into force on 7 March 2016 and some of our clients have already been required to complete and register their SMR/SMF and governance structures and maps.
This first stage is, however, just the beginning.
It’s simply not enough to create your SMFs, assign responsibilities and produce your map, then just hope for the best.
Firms must create monitoring assessment and management processes to ensure that their SM&CR responsibilities are fully delivered to the regulators’ satisfaction. They must also be able to record and evidence this and ensure that those in SMFs – the senior management team – have full oversight of the areas of responsibility they have been assigned and the forensic analytical tools and MI – that they have taken the ‘reasonable steps’ required to ensure compliance.
In October 2015, the Treasury announced that the SM&CR would be extended to cover the entire financial services sector, replacing the current Approved Persons Regime. This extension is expected to take place in 2018.
This event may seem to be some time away, but the point is that it will be applicable to all firms that currently have registered Approved Persons and will require the certification by the firm of most of these individuals. This will significantly increase the assessment of competence, fitness and propriety that the firm is expected to maintain and record. Firms will also be required to identify, register and map the senior staff that hold Senior Management Functions (SMFs).
As a minimum, firms will first be required to:
Additionally, firms will need to:
HRComplySoft is a complete solution for managing your firm’s SM&CR needs – along with broader T&C, Conduct and Performance.
Our system simplifies and automates all of these procedures giving you the monitoring, assessment and appropriate oversight tools required to ensure that these areas of governance, conduct, competence and responsibility are being delivered appropriately.
We have developed new functionality, enhancing HRComplySoft through the existing modular structure to ensure that firms can undertake all of this easily, cost effectively and through ONE SINGLE PLATFORM and subscription. We don’t require you to take separate subscriptions for each area of T&C, SMR and Conduct Management, or every relevant regulatory framework.