The Training Environment For Financial Services

Implementing Individual Accountability under SMCR

01 Oct 2019, London

10:00am to 4:00pm

Course Outline & Objectives

This focused workshop is specifically designed to help those responsible for implementing the Senior Managers and Certification Regime (SM&CR), prepare for the new regime, get to grips with the requirements and identify how best to embed the obligations within business as usual.

More specifically it will help you:

  • Effectively prepare for the new regime, by examining each of its elements and the interactions between them
  • Consider how to implement the requirements in light of the thresholds and obligations relevant to your firm and business model
  • Understand the longer-term implications of the regime and how to embed the requirements into your firm’s ongoing operating practices
  • Ensure you are up to date with the latest developments as the operational aspects of the extended regime are clarified
  • Benchmark your approach against market good practice

The programme is designed for delegates from FCA solo-regulated firms but will also help those from dual-regulated firms who are already subject to the SIMR requirements but who will have to upgrade to SM&CR.

Who will benefit?

Anyone responsible for setting up and implementing the SM&CR within a financial services organisation, especially individuals in Risk, Compliance and Operations. The course may also be of interest to Human Resources staff and to those in Internal Audit.

Training Approach

This workshop uses a combination of trainer input, knowledge sharing with interactive syndicate work and case studies. Class size will be limited to ensure a high quality learning experience.

Workshop 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.

Workshop Programme

Session Content
Background to Accountability II
  • Why SM&CR has replaced the Approved Persons regime
  • Regulatory aims and intentions
  • Individual accountability in the context of culture and governance
  • The banking sector experience
Overview of the requirements
  • Elements of the regime
  • Scope of the regime
One size does not fit all
  • Implications of the firm’s permissions and scale of operation
  • Core, enhanced and limited scope category firms
  • Insurance sector thresholds
  • Plans so far, quick wins and initial successes
The Senior Managers Regime
  • Senior Management Functions
  • The duty of responsibility
  • Statements of Responsibilities
  • Prescribed Responsibilities
  • Additional requirements for enhanced category firms
  • Anticipated challenges and how to overcome them
  • Who is in scope
  • The practicalities of Certification
  • Implications for performance management and appraisal
  • Capitalising on existing good practice
Fit and Proper
  • Criteria
  • Fit and Proper policies
  • Approaches to effective review
  • Dealing with failure
Conduct Rules
  • Who is in scope
  • Individual implications of the conduct rules
  • Additional rules for senior managers
  • Implications for performance appraisal criteria
  • Implications for disciplinary arrangements
SM&CR – more than just a project
  • Embedding individual accountability into business as usual
  • Maintaining continuing senior management engagement
  • and oversight
  • Fitting SM&CR into the three lines of defence
  • Implications for existing procedures
  • Keeping adequate records


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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