The banks already must comply with SM&CR

As the final deadline for SM&CR compliance looms in December 2019, it makes perfect sense to reflect on the learnings of the banks who rolled out the regime in March 2016. Earlier in 2019, the FCA interviewed senior banking leaders about their experiences of applying the SM&CR to their organisations. They were asked to provide SM&CR lessons and advice to other firms who will be adopting it this year.

Here were the highlights from the interview:

Q1. What are the potential benefits of the Senior Managers and Certification Regime?

• Provides the structure to allow everyone to do their jobs properly
• Helps to drive better accountability through transparency, clarity and support
• Reinforces appropriate culture, conduct and business principles
• Professionalises what it means to be a senior manager in an important industry
• Provides a clear framework to knit the organisation together

Q2. How has the SM&CR changed your organisation?

There were a number of changes and some of them started with fear around consequences. However, if people are clear about their roles, responsibilities, and accountabilities, then the quality of the interaction and the control over the business improves.

SM&CR raises the bar in terms of clarity as it flushes out the gaps or areas of ‘fuzziness’. Furthermore, it brings new focus to business objectives and clarifies escalation processes.

Q3. What is your advice to others implementing the SM&CR?

Don’t look at it from a fearful perspective – take it seriously but if people are clear about their roles and take their accountabilities seriously it will make your organisation more effective.

View it as a journey, it does demand a lot in terms of planning but make sure that it is owned by the business. Don’t label it a ‘Compliance’ or ‘HR’ initiative; ensure that the business own’s and embraces it. The business needs to understand and drive the implementation if you are to get the right level of update and embed the positive new behaviours.

To listen to the FCA video on this topic click here.

Final thoughts on SM&CR

Above we have outlined some valuable SM&CR lessons provided by the banks. From a change management point of view, it is important to move the SM&CR away from being a project and to embed it into business as usual. You can do this by looking for links with your existing processes such as objective setting and performance management, embedding a more robust control mechanism. Download our white paper on how to do this below.

Actus Comply provides a purpose-built SM&CR solution which can be used as a standalone compliance solution or as part of an end-to-end HR, performance management and compliance solution.

White paper: SM&CR and Culture Change 

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