Reasonable Steps - supporting Senior Managers under SMCR

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 focused briefing has been designed to support those in Compliance, Risk and Human Resource functions who are charged with helping SMFs maintain their competence and continue to meet their obligations under the SMCR. The session is equally appropriate for staff from solo or dual-regulated firms.

The session will provide a briefing on key issues which need to be factored into the professional development plans of SMFs in the current operational environment and provide insights into how to deliver appropriate refresher learning on SMF obligations and the concept of Reasonable Steps. The session will also include an opportunity for participant Q&As.

Topics covered include:

• Personal accountability expectations of SMFs and the statutory duty of responsibility
  
  
• The concept of reasonableness and Reasonable Steps
  
  
• The personal responsibility framework  
       - Statements of Responsibility
       - Individual and Senior Manager Conduct Rules

• Demonstrating Reasonable Steps
       - Documentary evidence of reasonableness in practice
       - Evidence of relationships within the senior team
       - Culture, style and purpose of the firm

• How reasonableness is determined