Reasonable Steps - meeting your Obligations as a Senior Manager

Outline & Objectives

With the Senior Managers and Certification Regime (SMCR) fully implemented across financial services and part of business-as-usual, firms now need to start to focus on the steps necessary to maintain their arrangements.  One element of this is the need for an annual review of fit and proper status of those approved to perform Senior Manager Functions (SMF). To ensure that SMFs continue to meet their competence and capability criteria, it is prudent to remind SMFs of their obligations under the SMCR and refresh their understanding of the protections offered to them through the concept of Reasonable Steps.

This interactive workshop has been designed as a development opportunity to support those who are approved as SMFs. The workshop is equally appropriate for both those who are newly approved and those who are more experienced as SMFs from either solo or dual-regulated firms.

The workshop will provide insights to the key obligations which are placed on SMFs in the current operational environment and the protections offered by the Reasonable Steps approach.  As well as exploring key issues through case study scenarios, the workshop will include opportunities for participant Q&As.

Attending will enable participants to:

• Identify the personal accountability expectations of SMFs and the statutory duty of responsibility
  
  
• Recognise the concept of reasonableness and Reasonable Steps
  
  
• Identify the key elements in the personal responsibility framework
      - Statements of Responsibility
      - Individual and Senior Manager Conduct Rules

• Explore how Reasonable Steps can be demonstrated    
      - Documentary evidence of reasonableness in practice
      - Evidence of relationships within the senior team
      - Culture, style and purpose of the firm

• Apply the concept of reasonableness to case study scenarios