Implementation of the Senior Managers and Certification Regime

Our client approached us in 2015 to help prepare for and implement the requirements of the new Senior Managers and Certification Regime (the SMCR).

As the branch of a foreign bank, the interaction between branch and head office management posed challenges when considering how to meet the requirements of the new regime. They wanted help to implement the regime in a manner proportionate to the nature and scale of the business.

Project Objectives

  • To establish who the regime applies to within the branch
  • To get the management team to understand the implications of the new regime
  • To implement the key requirements of the new regime
  • To scope and prepare appropriate procedures to ensure compliance with the requirements

How Bovill Helped

  • We helped the business understand the implications of the SMCR, and the regulators’ expectations of the management team within the branch and head office
  • We designed and delivered training to help the management team understand the new regime and its implications for them from an individual perspective
  • We helped the firm refine and articulate its governance arrangements (Management Responsibilities Map)
  • We provided guidance to members of the team to help them prepare their Individual Statements of Responsibilities
  • We worked with Compliance and HR to consider what processes needed to be put in place to ensure that the business was meeting the requirements of the new regime
  • We drafted procedures to cover more administrative elements of the SMCR, such as certification of fitness and propriety, conduct rule breach reporting, regulatory references, etc.
  • We delivered staff training on the conduct rules and what happens if an individual breaches a conduct rule.

Results

The client now has robust governance arrangements and operational procedures in place to ensure that it fully complies with the PRA and FCA’s requirements under the SMCR.

 

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