Extension of the SMCR to all financial services firms
As we all know, the Treasury has directed the FCA to extend the Senior Managers & Certification Regime (SMCR) to all financial services firms in the UK.
Many firms have still not started to prepare for their SMCR deadline of 9th December 2019.
Jonathan Davidson, Executive Director of Supervision – Retail and Authorisations at the FCA, said:
“Senior leaders should view the regime as a catalyst to inspire positive culture change at their firms. The SM&CR is an important way to ensure that individuals at all levels within firms take personal responsibility for their actions. It is good for business when employees buy into a firm’s purpose, feel personal accountability and are inspired to speak up (and to listen). This can be encouraged through the new conduct rules. This kind of culture supports a healthy and inclusive workplace for employees, innovation and sustainability, and thoughtful identification and mitigation of risk.”
We have created a 90+ point project plan for all firms, Limited, Core or Enhanced where we can conduct the entire project for you or you can buy our plan and conduct it yourself. Be warned, that the SMCR implementation has been estimated to take over 32 working days to implement at each firm.
There are three Elements for the project plan;
- Compliance Support – Provide a Support Package for the business – becoming your Compliance Department. See below for details
- Review and create a risk management framework for you to manage your business in accordance with the SM&CR and essential for all “Enhanced” firms, and extremely useful for all larger “Core” firms.
- The actual SMCR Project Plan
Part 1 Service Offered as part of Support – From £750 pm
The objectives of this compliance support and assistance include, and are limited to:
To provide services pertaining to;
- Helpline – Clarion Call – Our provision of a 24/7 helpdesk regarding any regulatory matter that you may need. Regulatory interpretation and application is a major strength. Unlimited calls (a £500+ value).
- Technical Help desk – Accessing any of our technical specialists that may be able to help.
- Compliance monitoring plan – reviewed and executed on an ongoing basis to tie in with your requirements. (a £9,000 value).
- Important issues summary – Horizon scanning – we provide you with noteworthy events that may impact your business in the next quarter as well as an overview of the next year’s planned occurrences from the regulator (a £1,000+ value).
- Compliance Doctor Newsletter – A weekly digest of regulatory and business news events, sent direct to your inbox each Friday lunchtime. (a £350 value).
- Template Documents – We can create and provide any documents that you may need. Specialist documents are arranged at extra cost on submission.
- Annual Risk Assessment & Report – A light version of our flagship benchmark audit and report. Details below. (a £2,000 value)
- Loyalty – Qualification for 20% discount on consultancy fees (typically rated at £750 per day) for any remediation work required as part of larger project plan.
- Regulatory Returns –Assistance in RMAR returns. (a £750 value).
Annual Risk Assessment & Report – Sectors and Areas Covered
- GOVERNANCE AND STRATEGY
- Management structure
- Allocation of responsibilities
- Risk management procedures
- Documentation status (Disclosure, Policies, TORs, operating and compliance manuals, etc.)
- GENERAL COMPLIANCE
- Compliance procedures within the firm (Post MCD, Treating Customers Fairly (TCF), Fin Proms, ABC etc)
- Conflicts of Interest Management
- Anti-money laundering and Anti-Bribery & Corruption Training
- Regulatory reporting issues
- Interviews with Directors/Partners or Manager(s) and Admin as required
- PERSONNEL MATTERS
- Remuneration policies – fair bonuses/rewards/incentives
- Training and competence (how/what/when & why)
- Staff retention
- Treating Customer Fairly (inform, update, deliver)/Conduct Risk
- Customer records (data protection/sanctions/KYC)
- Sales/service – Customer Journey & file reviews (minimal)
- Complaints – handling and reconciliation.
- Data security/protection measures
- REGULATORY EVOLUTION
- Level of preparedness for regulatory changes
Part 2 – Risk Management Framework – from £1,550 pm*
This will involve a full audit of your company and provide typically a 100-page report (a £4,600 value);
Risk appetite. Defining risk appetite and risk tolerance for operational risk and conducting regular reviews
Monitoring. Provide a risk monitoring system (paper based) for inclusion in all Management Meetings packs.
Action Plan/s. Record of all areas of controls and identification of design or execution weaknesses with remediation recommendations.
Risk Capital Budgeting.
Early warning risk system. Identifying crystallising risks provides greater control and increases money saving as well as improved reputation and creates a defined value when exit or retirement plans are enacted. It does this by;
- Better, more effective and more reliable operations;
- Reduction in losses from damages, threats, illegal activities and exploits;
- Lower cost of compliance; and
- Reduction in future potential damages.
Documentation for Risk Management. We provide you with a suite of documents which cover your existing controls, risk management and process mapped workflows.
Part 3 Actual SMCR Preparation Project – our 90+-point project plan from £1,550 pm*
Prepare your business through the multiple point project plan covering the 5 main areas of SMCR planning;
- SMCR. SMF and SORs in accordance with COCON 3 reference to COCON 4.
- Governance – in accordance with SC1 to SC4 of COCON as well as SYSC changes with reference to COCON 4.
- Training – Staff/CF and SMF training to demonstrate adherence to COCON 2.3
- MI – effective KPIs and KRIs to help you demonstrate how well your business is run.
- Certification regime. Implementing the regime and management thereof in accordance with COCON 2 & 4.
We have experience of implementing SMCR for the banking community.
* Fee correct if started before 19th May 2019, rising to £1,995 pm before 19th June 2019 and £2,450 pm before 19th July 2019.
Contact us for details of your package 0207 097 1434