For those in the financial services, the Senior Managers and Certification Regime (SM&CR) compliance should be a top priority. Since the FCA raised the standards for personal conduct, firms should ensure that they understand the new requirements in order to avoid potential regulatory sanctions. Sixth months after the FCA’s 31 March deadline for solo-regulated firms, are you confident about your firm’s SM&CR compliance plan?
ComplySci recently hosted a webinar on SM&CR compliance with Dan Ridler, Managing Director at BCS Consulting, and Ian Colquhoun, Chief Compliance Officer at Sona Asset Management. We highlight the key takeaways for your firm below.
- Develop A Clearly Defined SM&CR Model: Regulators expect firms to be consistently maturing their SM&CR programme. Do you have a documented process with clearly defined roles and responsibilities? Accordingly to Ridler, most firms achieve a high level of documentation, but fall short of detailing how the SM&CR programme supports and connects to overall business objectives. This is crucial to achieve scalability and automation.
- In Cases of Non-Compliance, Regulators Won’t Be Lenient: When the FCA extended its original deadline for solo-regulated firms to 31 March, it was in response to COVID-19 disruptions. That was the leniency period. Now, any non-compliance is at the risk of firms, as well as potential liability for Senior Managers. Typically, regulators will be speaking to firms about other matters not related to SM&CR, and during these interactions, will uncover SM&CR weaknesses.
- An SM&CR Solution Can Save Time and Resources: One of the big burdens of SM&CR compliance is keeping track of all the important paperwork and documentation. Colquhoun’s firm uses ComplySci SM&CR Workflow Management to automate SM&CR certifications and maintain an easily accessible audit trail within the ComplySci system for regulators. The best part? ComplySci makes it simple to clone forms for future use, saving compliance teams a significant amount of time and reducing the risk of human error.
“Don’t be complacent. Continuously review the SM&CR processes you have in place and keep evolving them with your organisation, which will no doubt continue to change.” ~ Dan Ridler, Managing Director, BCS Consulting