In Focus Collections
proper, and that there be better standards of conduct at all levels in banking firms. Based on these recommendations,
Parliament passed legislation in December 2013, leading to the FCA and Prudential Regulation Authority applying the SMCR to the banking sector. The FCA sets out its intention boldly: “The
aim of the SMCR is to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence.” As part of this, the SMCR aims to:
l Encourage a culture of staff at all levels taking personal responsibility for their actions. lMake sure firms and staff clearly understand and can demonstrate where responsibility lies.
However, when asked ‘how will your firm evidence the compliance expectations of the SMCR when it comes into effect on 9 December 2019?’ 43% said that they would use manual processes, and 35% that they would implement an SMCR software solution, with the remainder currently being undecided
Need for attention The good news is that, according to the research, the industry is aware of the need for attention to be given to this issue. Asked ‘is your firm already in the process
of implementing the FCA requirements under the SMCR’, just over 95% of respondents said that they were. However, when asked ‘how will your
firm evidence the compliance expectations of the SMCR when it comes into effect on 9 December 2019?’ 43% said that they would use manual processes, and 35% that they would implement an SMCR software solution, with the remainder currently being undecided. Again, when asked ‘does your firm plan
to implement an integrated GRC and SMCR software solution to improve your
Is your firm already in the process of implementing the FCA requirements under the SMCR?
Yes Head of Risk
Senior Managers & Certification
Regime (SMCR) Head of HR No Other Other
What is the key regulatory compliance supervision challenge facing your firm?
Systems and Controls
governance framework and processes’, there was also considerable room for decisions still to be made. In total, 35% said they would, and 24% said they would not, leaving 41% to say that they situation was still being evaluated. Likewise, when asked ‘how does your
firm currently manage and evidence FCA systems and controls (SYSC) compliance and risk-management governance controls’, 62% said they still rely on manual processes, a worry in a changing and demanding compliance landscape. So there is still a huge amount to be
decided as we go forwards into new regulation, but one thing is for certain: the challenge of requirements on senior industry professionals are coming and the industry needs to be prepared. CCR
Who, or which job role, within your firm is responsible for implementing the SMCR?
Head of Compliance
September 2019
www.CCRMagazine.com
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