Actus SEAR & SMCR Software – Affordable Effective Assurance

The Central Bank of Ireland (CBI) has now confirmed that it will be following the lead of the Financial Services Authority (FCA) in the UK by introducing a stringent individual accountability framework (IAF) for improved regulation of the financial services sector. Current indications are that firms will be expected to comply with this by July 2024 which isn’t far away!

The IAF includes the following key elements:

  • Senior Executive Accountability Regime (SEAR): This will require in-scope firms to set out clearly and fully where responsibility and decision-making lie within the firm’s senior management.
  • Conduct Standards: Common Conduct Standards are basic standards such as acting with honesty and integrity, with due skill, care and diligence, and in the best interest of customers, and will apply to individuals in all regulated firms. Senior executives will also have Additional Conduct Standards related to running the part of the business for which they are responsible.
  • Enhancements to the current Fitness & Probity (F&P) Regime:This will include clarifying firms’ obligations to proactively certify that individuals carrying out certain specified functions are fit and proper.
  • Amendments to the Administrative Sanctions Procedure (ASP): A key change will be the Central Bank’s ability to take enforcement action under the ASP directly against individuals for breaches of their obligations rather than only for their participation in breaches committed by a firm.

See the full IAF consultation paper, draft IAF regulations and guidance

Many of the requirements echo those of the SMCR regime in the UK which was introduced between 2016 and 2019 and Irish firms can benefit from the lessons learned by those who thought they could manage this manually. These were typical comments made by Actus Comply comments who joined us after the deadline: “Managing certification and conduct annually is going to be a bigger a job than we expected” or “We’ve done the mapping on excel but ongoing reporting and keeping it 100% accurate is a massive headache and the risk increases every year!” 

It is relatively easy to complete the mapping and assignment of roles but the challenge associated with the annual certification process, coupled with the pressure to keep all the data accurate and 100% up to date all the time is huge. With the shift in responsibility having moved from the firm to the individual, there is no surprise given the levels of personal liability likely to be similar to SMCR for the SEAR regime.

Spreadsheets and manual control mechanisms wont provide a sustainable audit trail that meets the CBI’s requirement of being able to demonstrate a solid SEAR control process, similar to that of SMCR. It wont take long for Irish firms to realise that managing Fitness and Probity using paper-based systems is never going to work. Irish firms need an affordable and reliable SEAR software solution and that’s why they are looking to Actus.

“Actus provides an easy to use but rigorous solution to our SMCR challenges”     
 Peter Cullum CBE – Chairman of Global Risk Partners

Simple, Purpose-built Software

Actus Comply eliminates these concerns with a simple, but highly effective SEAR and SMCR software solution. We have a purpose-built compliance module for assigning and tracking responsibilities with a full audit trail; clear reporting and a host of value-add features. Actus Comply also offers CPD; Certification and F&P management for the whole firm.

Actus Comply was designed in partnership with clients in the financial services industry to specifically meet the needs of the Senior Managers & Certification Regime providing the accountability, visibility and reporting that is required to ensure that regulatory compliance can be demonstrated with confidence.

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Actus Comply was designed in partnership with the Financial Services Industry to support SM&CR requirements and is equally relevant for other industries with regulatory obligations.

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Actus Comply Features

SM&CR Specific

  • Allocate and map SMR roles and statement of responsibilities (SORS)
  • Ability to delegate and track associated responsibilities without abdication
  • Configure and allocate role related responsibilities e.g. committee memberships
  • Freedom to set up and manage additional projects and responsibilities

CPD; Certification & Conduct

  • Freedom to integrate conduct and competence sign off into the annual appraisal
  • Recording of role-specific training and qualifications with automated alerts of expiry
  • Continuous Professional Development (CPD) tracking and reporting
  • Gather feedback and attach supporting evidence throughout the year against the employee record

Evidence of Assurance

  • Appropriate Controls and Measures with FCA ready reporting
  • Automatic compliance validation
  • Breach recording and management
  • Automated Certificate production and storage
  • Responsibilities map and real-time reporting
  • Full audit trail

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