It may seem quite a way off but the Senior Managers and Certification Regime implementation date will soon be upon us.
Now is the time to start thinking about implementing the requirements into your organisation. Here are some of the common pitfalls to avoid:
- Losing sight of SM&CR’s purpose: The new regime is far more than a replacement for the Approved Persons Regime. It is designed to ensure all staff are aware of how their actions can have an impact on the services and outcomes your firm provides.
- A lack of awareness of the conduct rules: The five conduct rules should become as well-known among staff as the six TCF outcomes. Firms should pay particular attention to (i) integrity, (ii) due care, skill and diligence and (iii) treating customers fairly.
- Not defining the practical steps needed to drive the right behaviours: This needs to be much wider than a quality assurance-driven incentive scheme.
- Failing to map responsibilities: Drawing up a responsibilities map enables senior managers to demonstrate full control over their certain areas and helps demonstrate good standards, even if your firm is not required to maintain one under the regulations.
Mike Harrison is associate director at TCC