Time To Rethink How We Manage SM&CR?

Julie Pardy

Julie Pardy

With more than 30 years service in the Financial Services industry Julie has spent many years at the coal face undertaking a wide variety of roles in banking from Compliance to Sales, Operations to Training.

We’ve talked about it for several years and now the final tranche of firms should have a fully functioning SMCR framework within their business and have hit the extended deadlines of 31st March. This was the date when solo-regulated firms needed to have:

  • Trained all relevant employees on the Conduct Rules.
  • Assessed all Certified Persons as being fit and proper to conduct their roles.
  • Submitted their initial information about Directory Persons to the Financial Services Register.


Of course, dual-regulated firms have been fully operational with SMCR for several years and have become accustomed to the pressures of managing the regime day to day. In fact, in December the PRA issued the results of its review into the implementation of SMCR in dual-regulated firms.

One of its key findings was:

“Although over 90% of firms reported that SM&CR had been incorporated into their business-as-usual practices in some way, only just over 50% felt that this went beyond simple regulatory compliance”.

In other words, much work is still required to ensure SMCR is more than an exercise in regulatory compliance, i.e. more than a ‘tick box’. And, given the messages from both regulators, particularly the FCA, about SMCR being the catalyst for creating wider culture change in financial services, SMCR needs to be much more embedded for it to become the foundation stone on which culture change can evolve..

At Worksmart, we have been working with our trade association partners to run webinars on living with SMCR as well as running our own regular virtual briefings. In these webinars, we’ve been asking attendees for their views and providing practical advice. In one webinar before Christmas, we asked attendees about what they were finding difficult about managing SMCR. The answers were revealing and, in summary, identified the sheer volume of administration as a significant challenge.

At our most recent Virtual Briefing on 16th March, during the session we asked attendees about their experiences of living with SMCR and their feedback was, again, revealing.

Polling results Worksmart webinar

Attendees identified challenges across all aspects of the regime, with managing Fitness & Propriety assessments ‘top of their list’. Given the number of ‘moving parts’ that need managing in SMCR, I suppose we shouldn’t be surprised by these findings. However, not being surprised doesn’t make it any less daunting a task administratively.

However, the next question asked of attendees provided some real insights into why firms are finding SMCR such a challenge to embed. Of the attendees responding, and there were over 100, not one said that their headcount had been increased to help manage SMCR and two thirds of delegates said they were managing the administration of SMCR with either spreadsheets or paper!

Worksmart Webinar Polling Result

Earlier I described SMCR as having a number of moving parts. From recording each change of senior manager responsibility to committee memberships to managing the multiple activities, is no mean feat.  Add into this the Fitness and Propriety assessments which demand quite wide-ranging assessment of individuals, then it’s no wonder that administering SMCR is both challenging and daunting for firms.

And, to be frank, managing this extended regulatory workload using paper and spreadsheets with no extra staff is like trying to run the 100 metres in a diving suit!

I appreciate that we at Worksmart have a vested interest, but in our view not using a dedicated SMCR solution is nothing short of setting yourself up to fail. Using a dedicated SMCR solution like Accord, our multi award-winning SMCR solution, enables central teams to more effectively oversee the regime, whilst retaining real control of both the timeliness and quality of their activities. In other words, only by using a dedicated solution can central teams step away from the day-to-day administration and concentrate on managing the quality of SMCR activity and exceptions, e.g. a member of the certification regime failing their Fitness and Propriety assessment.

Doing so will enable those responsible for managing SMCR to really focus on embedding SMCR and so be able to start responding the FCA’s challenge to firms that SMCR should not only be embedded, it should become the catalyst for culture change.

If you would like to know more about how Accord could help transform your SMCR administration, contact our friendly and knowledgeable team on: 01908 613613 or email us on:



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