The Training Environment For Financial Services

Senior Managers and Certification Requirements - the Role of HR

17 Sep 2019, London

9:30am to 4:30pm

Outline & Objectives

It is no longer possible for HR professionals in financial services organisations to leave all regulatory matters and responsibilities in the hands of the Compliance department. Under the FCA and PRA, regulation has extended into core areas of the traditional HR remit, such as the vetting of applications and applicants for significant roles and the setting and monitoring of core competencies. The advent of the Senior Managers and Certification Regime (SM&CR) calls for the full engagement of HR as well as providing a helpful platform from which to promote the value of the HR function to the business.

This focused workshop is specifically designed to help HR specialists contribute effectively to the implementation and ongoing operation of the SM&CR in their firms. The programme addresses the regulatory requirements that need to be met and provides an opportunity to update and refresh understanding of the regulators’ expectations. It also provides guidance on the practical steps HR can take to make SM&CR a success within their organisations. 

This course is designed for delegates from both PRA regulated firms, who are already subject to the SMR and Certification or SIMR requirements, and firms regulated solely by the FCA, who will face similar obligations shortly.

Attending will help you:

  • Keep up to date with the latest regulatory developments and priorities and the implications for HR
  • Implement appropriate arrangements to meet the requirements of the Senior Managers Regime, Certification and the learning and development associated with the Conduct Rules
  • Examine the impact of the SM&CR requirements on key areas of the regime such as Fitness & Propriety, Ongoing Competence, Performance Management and Discipline
  • Understand what the regulators expect of Senior Management Function holders and the HR processes and interventions needed to support them
  • Establish key HR risks, controls and indicators in respect of regulatory requirements
  • Understand how the SM&CR fits into the bigger picture of effective governance, individual accountability and the development of the corporate culture

Who will benefit?

Anyone responsible for key HR activities within a financial services organisation, including: Talent Management, Employee Benefits, Recruitment, Training, L&D, Organisational Development, Administration and Record Keeping.  The course is also valuable for individuals in Risk, Compliance and Audit with responsibilities for monitoring HR activities.

Training Approach

This course will combine lecture style presentations with practical examples and exercises. Delegate numbers will be limited to ensure a high quality learning environment

Course Leader

Charles Cattell is a consultant and training practitioner with extensive expertise across the financial services sector. He advises, trains and develops a broad range of financial services clients and their senior managers about the human aspects of regulation with a particular focus on managing people risk, the development of competence and expertise and the enhancement of corporate culture. His clients include banks, product providers, intermediary firms, and insurers with whom he works at a senior level on learning, leadership, regulatory and corporate governance issues. Charles also works extensively with trade associations, examining bodies and regulators, whom he has advised on competence and professionalism issues. He is a Chartered Fellow of the Chartered Institute of Personnel and Development, a Chartered Member of the Chartered Institute for Securities & Investment and a Chartered Insurance Practitioner and an Associate of the Chartered Insurance Institute.

Course Programme

Session Content
The regulators and rules governing people
  • The suitability of resources
  • How the rules apply to different roles
  • Regulation versus employment law
  • Regulatory grip over people
  • Regulatory approaches to supervision and enforcement
The challenge of individual accountability
  • Strengths and limitations of the Approved Persons Regime
  • APER, SIMR and SM&CR in a period of transition
  • Winners and losers under the new arrangements
Application of the Senior Managers and Certification Regime
  • The scope of the current regime
  • Extensions to the insurance regime
  • Scope of the FCA solo-regulated regime
  • Implications of the firm’s activities and scale of operation
Elements of the Senior Managers and Certification Regime
  • Features of the Senior Managers Regime
  • Features of the Certification requirements
  • Obligations under the Conduct Rules
Ownership of and responsibility for the regime
  • Roles and opportunities for HR
  • The nature of senior management engagement
  • The role of the control functions (Risk, Compliance and Internal Audit)
  • The role of the Company Secretary
What we (should) have in place already
  • Managing the recruitment process
  • Learning and development, training and competence
  • Performance management and appraisal
  • Provision for Continuing Professional Development
  • Engagement with the Remuneration Code
  • Whistleblowing
Practical aspects of implementing the regime by HR
  • Managing the regulatory reference requirements
  • Determining fitness and propriety
  • Obtaining regulatory approval
  • Assessing and confirming competence
  • Administering the Certification Regime
  • Certification and Statements of Professional Standing
  • Providing training on the Conduct Rules
  • Dealing with disciplinary issues
More challenging situations
  • Amending contracts and policies
  • Dealing with disciplinary issues
  • What happens when an individual’s fitness and propriety is in doubt
  • Exits and settlement agreements
Transitional considerations
  • Determining the firm's approach
  • Identifying the scope of certification
  • Preparation of senior managers
  • Preparatory activities and when to start them
Reporting and record keeping
  • Providing relevant information to prescribed responsibility holders
  • Records of responsibilities, reviews and decisions
  • Establishing and recording precedents
  • Providing reports to the regulator
  • Making notifications to the regulator
  • Using the SM&CR to position HR as a risk management function
  • Using SM&CR to mitigate people risks 
  • The impact of SM&CR on governance and corporate culture
SM&CR and the broader HR agenda
  • Using the SM&CR to position HR as a risk management function
  • Using SM&CR to mitigate people risks 
  • The impact of SM&CR on governance and corporate culture 


This course can be delivered in-house at a time and location to suit your business and tailored to suit your people and organisation. We can also create bespoke training when something very specific is needed.Please contact us to discuss your requirements in more detail and at no obligation.

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