Although the FCA extended the SM&CR implementation period for solo regulated firms until 31 March 2021, firms that plan ahead and finalise SM&CR compliance now will be in a stronger position to ensure complete compliance. SM&CR Compliance is a top priority for the FCA; as a result, it is important for firms to build an SM&CR model that is clearly defined, understood in detail, and continuously evaluated.
We recently hosted a webinar with the experts at BCS Consulting on building a successful SM&CR operating model. For those who could not attend, or are looking for a summary, we have compiled the key takeaways below:
Top 3 SM&CR Compliance Challenges
- Incorrect identification of Senior Managers that leaves individuals unfairly exposed to regulatory sanctions
- Poor audit trails of potential Conduct Rule breaches
- Inadequate BAU operating models that do not have clearly defined roles and responsibilities
3 Best Practices for a Successful SM&CR Model
- SM&CR teams should be embedded in relevant governance to gain visibility, with a clear and consistent view of allocated responsibilities
- SM&CR processes should be mapped around existing processes, and controls should be designed, monitored, tested, and continuously improved
- SM&CR systems should be carefully designed to meet your firm’s requirements, and new tools must be operationalised and maintained
To access the full webinar recording, reach out to info@complysci.com.