Senior Managers & Certification Regime (SM&CR)

Enhance governance, accountability and culture through SM&CR compliance

Mitigating personal and firmwide regulatory risk

The Senior Managers & Certification Regime (SM&CR) was introduced to strengthen culture and governance in firms through promoting greater individual accountability and enhanced standards of personal conduct. SM&CR is central to the culture and conduct agenda of the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA).

Recently, firms have experienced changes in daily priorities, operational changes including remote working, altered management control and Board oversight, deferred risk governance and internal control processes and activities.

Financial services regulators regularly remind firms about ongoing SM&CR obligations and their expectations of firms and Senior Managers Regime. More needs to be done to further embed SM&CR within organisations and mindsets.

Given the increased focus on individual accountability, Senior Managers must demonstrably exercise proper oversight and meet regulatory expectations to manage their own personal regulatory risk. Our regulatory compliance specialists provide training and help firms assess their SM&CR compliance to further strengthen and embed their SM&CR framework.

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Senior Managers & Certification Regime (SM&CR) Brochure

Senior Managers & Certification Regime compliance

Senior Managers and Certification Regime

We support solo-regulated and dual-regulated firms’ need to ensure compliance with the requirements of the Senior Managers and Certification Regime in the following areas:

Providing independent assurance to the Board and Senior Managers on, and remediation of SM&CR frameworks, covering: Policies, Statements of Responsibilities (SORs), Management Responsibilities Maps, Fitness & Propriety assessment process, breach notification process and records, Conduct Rules training process and records, recruitment process (including regulatory references)
Independent review, testing and remediation of reasonable steps framework and documentation to ensure they are fit for purpose, providing peace of mind to Senior Managers
Assisting new Senior Managers in understanding their regulatory responsibilities and meeting their application requirements (e.g. SORs, skills gap analysis, learning & development plan, induction programme)

SM&CR training is an opportunity for firms to embed the right culture. We develop one-off or ongoing SM&CR and Conduct Rules training programmes tailored to the team’s requirements, delivered by regulatory compliance specialists.

Independent assurance on SM&CR compliance

Our regulatory compliance consultants at Xcina will collaborate with firms to deliver SM&CR advice and achieve the following:

An independent review or support using specialist external resources to provide the Board and Senior Management with independent assurance that relevant SM&CR policies, procedures and documentation are in place and operating effectively to mitigate the risk of non-compliance with SM&CR requirements.
Providing peace of mind to individual Senior Managers by enabling them to demonstrate compliance with Senior Manager Conduct Rules, and to evidence the discharge of Senior Manager prescribed responsibilities relating to the Senior Manager Regime, Certification Regime, and Conduct Rules, as well as overall and other responsibilities – thereby mitigating individual accountability risk.
Strengthening and further embedding of the SM&CR framework including Conduct Rules to sustain governance, accountability and a positive culture.
Regular sharing of insights into relevant regulatory trends and developments, as well as leading practices.

How SM&CR advice from Xcina Consulting can add value

Senior Managers and Certification Regime

Clients benefit from our extensive subject matter expertise as well as leading practices gained from assisting organisations across financial services sectors with their SM&CR requirements.

Our SM&CR compliance specialists have many years’ practical experience on the subject across a range of firm types and are at the forefront of the latest developments, regularly conducting industry surveys, providing thought leadership and speaking at industry conferences on the topic. Our team includes a blend of former Senior Managers, Heads of Compliance and Regulators. They provide pragmatic value-adding solutions tailored to your specific context, not generic impractical recommendations.

We share with you our experience and provide knowledge transfer as required including training so that your team is equipped to use and maintain your SM&CR framework independently going forward.

We provide a cost-effective solution enabling you to access to subject matter expertise and advice upon request.

What our clients say

Lindsey and Xcina have assisted us with bespoke SMCR training and reviewed associated documentation. They have also assisted with various ad hoc compliance review requests. We have always found Lindsey to be very helpful and informed on the relevant subject matter. He has always been quick to respond to our requests and has been a pleasure to work with.

Chris Sloan, Director ClucasGray Investment Management UK Limited

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