GDPR Briefing

It is several months since the FCA published its proposals on how it intends to roll out the Senior Managers & Certification Regime (the SM&CR) to the wider financial services industry.  Whilst the rules will not be finalised for some time and the implementation date will not be until the end of 2018 at the earliest, savvy firms have recognised that there is much to do, and are already seeking to get on the front foot and start their implementation projects.

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Bovill and Fox Williams teamed up to deliver two seminars where we considered some of the more challenging aspects of the new regime and how best to scope out your implementation project.

Prem Griffith, one of Bovill’s SM&CR experts, was joined by Jo Chatterton and Helen Farr, both employment lawyers and members of the Fox Williams SM&CR team, to provide a fascinating insight into the challenges facing FCA-regulated firms as they prepare to implement the new regime.

Session 1:  Challenging aspects of the new regime


8:00-8:15 Registration and breakfast
8:15-8:20 Welcome and opening remarks
8:20-8:50 Challenging elements of the SM&CR
Prem Griffith reminded attendees of the key elements of the new regime and outlined some of the more problematic and time-consuming aspects of the regime.
8:50-9:20 Tricky employment aspects of the new regime
Jo Chatterton and Helen Farr focused on the implications of the new regime for your people and helped answer questions including: Who will be your senior managers? How will you select them? Do you need to restructure to manage the new regime? What are the new duties on this population and how do they dovetail with their employment rights?
9:20-09:50 Interactive Debate
The regime is largely focused around the concept of individual accountability and Senior Managers will be subject to a ‘duty of responsibility’. Should a regulatory breach occur, responsible Senior Managers will need to demonstrate they took all ‘reasonable steps’ to out prevent the breach from occurring. In this session, we outlined a number of theoretical scenarios and invited attendees to debate what ‘reasonable steps’ they might take when faced with such a scenario.
09:50-10:00 Questions & Answers


Session 2:  How to implement the SM&CR


8:00-8:15 Registration and breakfast
8:15-8:20 Welcome and opening remarks
8:20-8:50 What a successful SM&CR implementation project looks like
Prem will reflect upon his experiences from helping Bovill’s banking clients with their own SM&CR implementation leading up to March 2016 and outline his views on what a successful SM&CR implementation project might look like.
8:50-9:20 How to implement the regime for your team
Building on the points covered in the first seminar, Jo Chatterton and Helen Farr will focus on the steps you need to take to successfully implement the new regime. With a particular focus on the tricky elements of managing certification and points you need to consider when managing the new regulatory reference process.
9:20-09:50 Interactive Debate
How do you assess if a certified person is fit and proper to undertake his or her role? What do you need to include in a regulatory reference? We will focus on some tricky areas where judgment needs to be exercised in an interactive case study building on the points addressed by the speakers.
09:50-10:00 Questions & Answers

Thinking about these matters now will help firms ensure they are well placed to minimise the impacts of any necessary changes and effectively manage the transition to the new regime.

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29 November 2017 (iCal | GCal)

Bovill London

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Bookings are closed for this event.