SMCR Model

3 Best Practices for a Successful SM&CR Model

Although the FCA extended the SM&CR implementation period for solo regulated firms until 31 March 2021, firms that plan ahead and finalise SM&CR compliance now will be in a stronger position to ensure complete compliance. SM&CR Compliance is a top priority for the FCA; as a result, it is important for firms to build an SM&CR model that is clearly defined, understood in detail, and continuously evaluated.

We recently hosted a webinar with the experts at BCS Consulting on building a successful SM&CR operating model. For those who could not attend, or are looking for a summary, we have compiled the key takeaways below:

Top 3 SM&CR Compliance Challenges

  • Incorrect identification of Senior Managers that leaves individuals unfairly exposed to regulatory sanctions
  • Poor audit trails of potential Conduct Rule breaches
  • Inadequate BAU operating models that do not have clearly defined roles and responsibilities

3 Best Practices for a Successful SM&CR Model

  • SM&CR teams should be embedded in relevant governance to gain visibility, with a clear and consistent view of allocated responsibilities
  • SM&CR processes should be mapped around existing processes, and controls should be designed, monitored, tested, and continuously improved
  • SM&CR systems should be carefully designed to meet your firm’s requirements, and new tools must be operationalised and maintained

To access the full webinar recording, reach out to