Taking stock - What have we learnt so far?
There’s plenty of talk about the ‘new normal’ and although it’s natural to think about it being ‘new’, is it simply a turbo charged part of our planet’s evolution?
As we are now over half way through 2018 and SMCR regime begins next year, it might be timely to remind everyone of what they need to be doing now to prepare.
“Form K must be accompanied by a Statement of Responsibilities for each Senior Management Function (SMF) and an overall management responsibilities map.”
It seems like a strange way to begin an article but as we are now over half way through 2018 and SMCR regime begins next year, it might be timely to remind everyone of what they need to be doing now to prepare.
“The SMCR will affect the most senior management, with board members (or equivalent) and those who have significant influence, or the ability to cause significant harm to a firm’s business, being assessed and registered as falling within the Senior Managers requirements…”
Although there are a number of issues to consider, there are four which need to be considered now:
The area we will look at in this article is the first one – statements of responsibility – as it is the one that firstly, you should already have some structure for and secondly, because it is the area that often can take the most time to agree.
Having said that, often firms do not have a clear map of responsibilities or accurate job profiles, therefore we will use the term ‘job specifications’, which is a set of specified job responsibilities that each Senior Manager has accepted and agreed is their responsibility within the firm.
Often, firms will have ensured that more junior employees have these specifications, but senior people often do not due to taking joint responsibility or switching from area to area of the business depending on the day of the week!
This is not necessarily a problem as this is often how brokers will work, but the bottom line is that a named individual will take ultimate responsibility for specific issues within the firm – money laundering for example.
This applies to enhanced firms only. Enhanced firms (this includes intermediaries, although not sole traders) must prepare and maintain a responsibilities map. This is a single document that sets out the firm’s management and governance arrangements
Practical steps that you should be taking: