‘Final call for SM&CR’ – Are you sure your preparations are taking you in the right direction?
Read “Rising to the challenge of the Certification Regime”, by Julie Pardy to help ensure your SM&CR journey ends up at the right destination!
Worksmart have been helping financial services firms introduce the Senior Manager & Certification Regime (SM&CR), into their businesses since late 2015.
During that time, the team have accumulated a wealth of experience of how different firms have implemented the regime. It’s both interesting to note and no doubt re-assuring for many that in all the implementations we have been involved in, no two firms apply the SM&CR regime in exactly the same manner. This will be re-assuring for the FCA who have made it clear that they don’t want templated solutions and that they are looking for SM&CR to provide a robust governance framework for firms in support of their existing processes rather than force firms to build a raft of new ones.
When firms initiate their SM&CR implementation projects, their project teams head straight for the new regulation, deconstruct that regulation then start planning their project based on implementing every component of the regulation.
‘What’s wrong with that?’ I hear you say. On one level, absolutely nothing, this approach is necessary to ensure the firm complies. However, the well-known saying, ‘can’t see the wood for the trees’ comes to mind. When project teams jump straight into the detail, the wider issues are often lost.
The guiding principle of SM&CR is that the regulator is looking for SM&CR to deliver both behavioural and cultural change within firms. When project teams get into ‘project mode’ these wider issues can easily get left behind as there is a granular level of focus on the details with the bigger picture lost amid project planning and delivery schedules.
Julie Pardy has worked with a wide variety of firms across a multitude of SM&CR implementations and shares her experiences in a very readable and informative guide called Rising to the challenge of the Certification Regime.