Effectively implement the SM&CR


The Senior Managers and Certification Regime (SM&CR) increases business leaders’ accountability for the areas and management functions they are responsible for. But it is far more than just another regulatory initiative aimed at senior managers - if the ethos of the rules are embedded within a firm, the regime will help foster good conduct at all levels of a firm, to the benefit of customers and markets.

If you are currently working toward the 9th December 2019 implementation deadline of the Senior Managers and Certification Regime, we can help you.

Huntswood has developed a comprehensive suite of solutions to support firms through a successful implementation of SM&CR, based on our extensive experience of supporting banking, insurance and solo-regulated clients.

Huntswood’s SM&CR Suite

Huntswood’s tailored SM&CR Suite covers key areas within the regulation that will help ensure your firm is fully prepared to implement the new regime for the long term, as well as maximise the operational and commercial benefits to be gained.

The suite can form part of a holistically managed programme of support or be used in discrete elements, as outlined below:

We will undertake a focussed review and analysis of the following areas to inform your firm’s future SM&CR approach:

  • Organisational structure and reporting lines
  • The role and make-up of individual committees and their terms of reference
  • Governance arrangements and appropriate alignment with your firm’s operating model
  • Content and distribution of management information (MI)

We then develop a tailored project plan, setting out our findings and recommendations for the implementation involving:

  • Identifying and allocating Senior Manager Functions (SMFs)
  • Recommending which individuals at the very top of the organisation have ultimate responsibility for certain ‘prescribed responsibilities’
  • Articulating how these responsibilities map to Statements of Responsibilities and the Management Responsibilities Map
  • Putting in place the process to certify specific individuals and ensure they are ‘fit and proper’ to perform their role
  • Identifying the most efficient and effective approach to integrating SM&CR into your current operating / organisational model and policy framework
  • How to best execute firm-wide change

If required, our SM&CR specialist project managers can support your team to execute the actions that will ensure a successful and timely implementation. This will include engaging relevant stakeholders, setting timelines and managing the SM&CR implementation plan.

We can also provide assurance on governance and committee structures, role allocations, regulatory documentation.

Our SM&CR Toolkit includes key templates and guidelines for developing documentation in line with FCA requirements, including:

  • Project plan covering all required work streams
  • Responsibilities Maps and Statements of Responsibilities
  • Annual ‘fit and proper’ policy and certification procedures
  • Handover policy and certificates
  • Defining ‘reasonable steps’ and creating “living wills”
  • Breach reporting policy
  • Regulatory references policy
  • Whistleblowing policy
  • List of changes required to the employee handbook
  • Record keeping, meeting minutes and documentation policy

Our SM&CR Academy includes ready-to-tailor workshops and eLearning courses that support all employees, certified individuals and senior managers in the transition to SM&CR.

Senior Management Function (SMF) workshop

This full day workshop helps to ensure the SMF population understands the impact of the new Regime on them personally, their responsibilities, and how they undertake their day-to-day roles. It explores the new concepts and responsibilities that Senior Managers now have such as Duty of Responsibility and Handover procedures. It also provides a deeper look at the Certification Regime, the role Senior Managers play in assessing their Certified delegates as ‘fit and proper’, and a thorough exploration of the Conduct Rules for individuals and Senior Managers

This full day program is designed to meet requirements for training on the Conduct Rules. Alternatively, firms may opt for Senior Managers to attend the Certified Individual workshop at a later date.

Certified Individual (CI) workshop

This half-day workshop will help ensure the CI population understand the impact of the new Regime on them personally, their responsibilities, and the practical steps they need to undertake to ensure compliance. It also guides them through the ‘fit and proper’ certification considerations, as well as how the Conduct Rules apply to them and their teams.

This program meets the requirements for training on the Conduct Rules.

ELearning Module

This module provides a base level of knowledge to staff about the Regime and the obligations it places on firms and individuals. The module will use a combination of presentation, interactive case studies and knowledge tests. There will be an assessment at the end of the module to ensure that staff have engaged and attained competence. A structured conversation with the manager or coach should follow to enable application of the Conduct Rules to the individual’s role and responsibilities.

Completion of eLearning plus a structured coaching conversation meets requirements for training on the Conduct Rules.


Key Benefits

  • Gain assurance over your firm’s implementation plan and future approach
  • Mitigate regulatory and reputational risk through identifying and addressing any areas of non-compliance early

  • Create a more effective operating model by enhancing the transparency of accountability within your business

Why Huntswood

Established and proven approach to supporting firms in this area

Comprehensive understanding of SM&CR from a regulatory and operational perspective

Tailored solution – able to support on all aspects or specific elements as required