Thinking Beyond Implementation

With only a few months to go until the implementation of the Senior Managers and Certification Regime (SM&CR), firms should now be aware of what they need to do to be ready for the new regime.

Arguably, the new regulation should be treated not just as a list to be ticked off by 9 December 2019, but also as an opportunity to embed genuine cultural change throughout an organisation.

SM&CR shouldn’t stop with the regulatory requirements being covered off – it needs to go beyond that.

Feedback from the banking sector, where SM&CR has been in force since 2016, is that the regime has had a generally positive impact. Some banking leaders have said that the regime has helped drive accountability, provided clarity on who does what in an organisation and reinforced healthy cultures.

Vis Raghavan, CEO of EMEA, JP Morgan said that SM&CR, “is really around reinforcing what we stand for. It is reinforcing the culture, the conduct, it is the how we do business principles.”

SM&CR is something that firms should embrace and take positives from, rather than resisting change. That is why it’s important for firms to consider what they need to do to prepare for implementation, but to think beyond this too.

What does this mean in practice?

By increasing individual accountability and defining responsibilities, it is hoped that organisations will be clearer on their purpose, their objectives and the standards they need to work to. Remember that the Conduct Rules apply, not just to approved individuals, but to the majority of employees in a firm (excluding ancillary staff). Leaders need to set the tone from the top, rewarding positive behaviours and not incentivising those that might cause harm to consumers.

If firms embrace SM&CR and create healthy working environments, the benefits will be wide-reaching. An organisation where everyone understands their responsibilities and the standards expected of them, will be more robust.

SM&CR is intended, as in the banking sector, to bring lasting change. If firms are proactive now, it will become business as usual – and they are more likely to reap the benefits of improving their organisation’s culture.

December may seem a relatively long time away when we’re in the middle of summer, but in terms of preparation, time is moving quickly. If you think you need any help regarding SM&CR, please get in touch.