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SM&CR | Peruse our blogs for the latest, fresh perspective on navigating the maze of global regulations and upcoming milestones. This is your shortcut to staying ahead, packed with insights and expert tips from the forefront of GRC innovation.

Is SM&CR working?

accountability, SM&CR, audit trail

The SM&CR review was announced as part of the Edinburgh reforms towards the end of 2022, with HM Treasury indicating that “ some stakeholders have raised concerns about their experiences of specific aspects of the regime .” Consequently, the government is assessing...

Why Managing Conflicts should still be on your agenda!

wealthmanagement, consumerduty, compliance, corporate governance, risk management, conflicts, monitoring, SM&CR

Conflicts of interest is a subject matter that should be relatively easy to understand and as such, straightforward when it comes to compliance. Why then do we hear of senior managers who have failed to declare a potential conflict or to recuse themselves from related...

SM&CR: an update for FMIs

accountability, oversight, risk management, SM&CR, FMIs

UK Government issued a consultation paper last year setting out its proposals to replicate the Senior Managers & Certification Regime (SM&CR) for Financial Market Infrastructures (FMIs), who are not authorised firms. Here we look at the outcome of that consultation....

Do amended CPD requirements offer greater flexibility?

CPD, SM&CR, competence, audit trail

One of the fundamental obligations applicable to all regulated firms is the need to implement appropriate processes to manage risks. One such risk is that of providing unsuitable advice to consumers. This area has been a regulatory hot topic for some time. Remember the...

Assess & Prove Competence

governance, accountability, culture, corporate governance, oversight, Code of Conduct, SM&CR, competence, audit trail

The Senior Managers & Certification Regime (SM&CR) was first introduced in 2016 for banks and then phased in until it was finally extended to include the remaining regulated firms at the end of 2019. SM&CR aims to encourage greater accountability within firms whilst...

Has SM&CR made a difference?

governance, accountability, culture, remuneration, SIMR, SM&CR, certification, competence

The Senior Managers & Certification Regime (SM&CR) for insurers took effect in December 2018. As part of the Solvency II regime, insurers were already subject to the Senior Insurance Managers Regime (SIMR) introduced in 2016. Despite that, there were some new...

Accountability in Financial Services

governance, accountability, SM&CR, MIC regime, FAR, BEAR, SEAR

Since the financial crisis of 2008 regulators worldwide have been introducing reforms to improve individual accountability within firms. Regulators were criticised for their lack of action and not preventing the crisis. Further criticism was aimed at firms’ failings...

Creating Resilient Payment Services

governance, third parties, accountability, assessments, corporate governance, oversight, breach management, operational resilience, monitoring, SM&CR, data sharing

This was the view of the Payment Systems Regulator (PSR) back in 2015 when the PSR was still relatively new. Six years later and it’s fair to say that payments systems are even more critical today. It’s a message echoed by the Bank of England (BoE) and evidenced by the...

FMIs, Get set for SM&CR

accountability, SM&CR, certification, conduct rules

HM Treasury issued a consultation earlier in July. The proposals signal HMT’s intention to extend the Senior Managers & Certification Regime (SM&CR) to include Financial Market Infrastructures (FMIs). Interested parties should submit their responses by 22 October 2021....

Operational Resilience – Is Outsourcing on your Radar?

governance, third parties, oversight, risk management, operational resilience, SM&CR, outsourcing

With the publication of final policy statements there is a clear message that firms must look externally at third party relationships as part of their Operational Resilience framework. The requirements are designed to promote stronger and more effective governance of...

HR & Compliance – Bridging the Gap in SMCR

governance, accountability, culture, SM&CR, competence

Since the introduction of the Senior Managers and Certification Regime (SM&CR), it has been interesting to see how and where firms have allocated most of their resources to comply with the new rules. Implementation tends to follow one of two strategic approaches:...

SMCR Responsibilities – Documenting Risks and Controls

governance, accountability, culture, corporate governance, SM&CR, competence

In light of the turbulence caused by the Covid-19 pandemic, SMCR may have been pushed down the priority list for most firms for now. The disruption has however given rise to a number of practical and compliance challenges which have a direct and imminent impact on...

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