ComplySci recently hosted a webinar on SM&CR compliance with Dan Ridler, Managing Director at BCS Consulting, and Ian Colquhoun, Chief Compliance Officer at Sona Asset Management. We highlight the key takeaways for your firm below.
- Develop A Clearly Defined SM&CR Model: Regulators expect firms to be consistently maturing their SM&CR programme. Do you have a documented process with clearly defined roles and responsibilities? Accordingly to Ridler, most firms achieve a high level of documentation, but fall short of detailing how the SM&CR programme supports and connects to overall business objectives. This is crucial to achieve scalability and automation.
- In Cases of Non-Compliance, Regulators Won’t Be Lenient: When the FCA extended its original deadline for solo-regulated firms to 31 March, it was in response to COVID-19 disruptions. That was the leniency period. Now, any non-compliance is at the risk of firms, as well as potential liability for Senior Managers. Typically, regulators will be speaking to firms about other matters not related to SM&CR, and during these interactions, will uncover SM&CR weaknesses.
- An SM&CR Solution Can Save Time and Resources: One of the big burdens of SM&CR compliance is keeping track of all the important paperwork and documentation. Colquhoun’s firm uses ComplySci SM&CR Workflow Management to automate SM&CR certifications and maintain an easily accessible audit trail within the ComplySci system for regulators. The best part? ComplySci makes it simple to clone forms for future use, saving compliance teams a significant amount of time and reducing the risk of human error.
“Don’t be complacent. Continuously review the SM&CR processes you have in place and keep evolving them with your organisation, which will no doubt continue to change.” ~ Dan Ridler, Managing Director, BCS Consulting