"We believe it’s important that firms start to prepare early for the SM&CR to fully understand the impact on their businesses"
The SM&CR guidance is applicable to all firms regulated by the FCA across pensions, investments, mortgages and protection.
The Hub provides an overview of the SM&CR and explains how firms will fall into the different tiers of the regime, which will be determined by the size and structure of each firm.
Bank hall says larger advisory firms in particular should consider the changes early ahead of the deadline.
Carl Wallis, head of group compliance at Bankhall, said: “We believe it’s important that firms start to prepare early for the SM&CR to fully understand the impact on their businesses, which is why we have launched the Hub now. We’re already working with firms on a one to one basis to help them understand what the SM&CR means for their individual businesses. We know that larger firms, in particular, risk running out of time if they don’t engage and understand the work involved, as it’s likely to lead to fundamental discussions at a senior level in terms of governance structures and the boundaries of responsibility for each individual senior manager.
“The SM&CR aims to increase individual accountability and ensure it is easy to establish exactly who is responsible for what within firms. One of the key things we would stress is that implementation should be much more than a compliance exercise; treating it as such largely misses the point of the regime, which is about ownership, accountability and the culture that exists across all senior managers within each firm.
“The SM&CR was implemented for PRA firms almost two years ago. We have looked at the lessons learned from this to give ourselves a full understanding of what good looks like. Bankhall is working with firms and providing practical guidance to help them to get this right, and we will continue to develop the support on our SM&CR Hub ahead of the final FCA rules followed by implementation on 9 December 2019.”
