The Senior Management & Certification Regime (SM&CR) comes into effect on 10th December 2018 for Insurance and re-insurance firms.
The new regime significantly increases the accountability and competency requirements for individual senior managers in addition to prescribing behavioural expectations through the conduct rules applicable to all employees and individual Senior Managers.
The key purpose of the SM&CR regime is to encourage a culture of individual responsibility at senior manager levels and require firms to take charge of the behaviours of staff at all levels of the firm. Key considerations ahead of the effective date should include ensuring that:
- Ongoing activity to achieve compliance is properly oversighted and sufficient resources are availed to complete outstanding activity;
- All the relevant documentation has been prepared, reviewed and shared;
- Senior managers are aware of their increased liability;
- Appropriate infrastructure has been implemented to support senior manager oversight of their areas of responsibilities;
- Training has been provided across the business on relevant aspects of the SM&CR; and
- Mechanisms for ongoing support have been established e.g. to monitor ongoing compliance, respond to questions, address breaches, escalate issues and engage the regulatory authorities.