The Senior Managers & Certification Regime (SMCR) Overview
Organisations with entities operating in the United Kingdom must comply with SMCR, a regulatory framework designed to increase the accountability of senior financial services executives. Detailed rules, promulgated by the UK’s Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA), govern implementation of SMCR and associated Conduct Rules.
For successful ongoing compliance, these regulations require ongoing processes. Blueprint’s seamless solution creates workflows to manage every step of the process, including:
- Data Management
As a standard module in our entity management platform, Blueprint’s SMCR Manager provides full integration with our state-of-the-art application. By eliminating spreadsheets, manual reconciliation, outdated and dispersed data, SMCR Manager provides timely, accurate, effective and ongoing compliance.
Construct Ongoing SMCR Compliance Framework
SMCR is far from a one-and-done compliance task. Recently expanded to all firms operating under the jurisdiction of the Financial Conduct Authority (FSA), SMCR includes numerous specific requirements. Organisations must allocate functional responsibilities to senior managers, create a map that reveals the constellation of management responsibilities and assess the fitness of employees in specific roles. This information must be certified and updated annually.
Without access to organisational data across entities, SMCR compliance is much more complex. But that’s only the first step. Organisations need mapping capabilities, surveys and automated workflow tools to ensure compliance. Integrating all of the functions necessary for compliance removes a significant burden from legal and compliance teams, freeing up their time and energy for value-added tasks such as analysis.
Build Senior Managers Regime Lists
Blueprint’s SMCR Manager integrates seamlessly with Blueprint’s existing data to ensure ongoing SMCR compliance. Data required for SMCR compliance can be gathered from data already in the system. Collect additional data with pre-filled and customisable survey tools that allow data to be gathered quickly and easily. Customised workflows ensure that surveys are sent out and completed in a timely fashion for appropriate filing.
These tools are critical, as the Senior Managers Regime applies to individuals performing a senior management function, whether based in the UK or not. Every identified senior manager must have a statement of responsibilities attached to their role. These statements of responsibilities enable the Financial Conduct Authority to identify and hold responsible individuals accountable if, in the FCA’s view, they did not take “reasonable steps” to prevent an event from happening that could have been prevented. In addition, the FCA must approve all individuals in this role, and if responsibilities change, filings must be updated.
Construct Responsibility Map
Blueprint OneWorld’s ChartItfacilitates the construction of the required responsibility maps. An industry-leading tool for organisational charting and entity relationship diagramming (ERD), ChartIt can be customised to powerfully visualize data.
Map all relevant senior management responsibilities across the business and any related reporting lines within each individual entity. Click on links to specific senior manager functions and their associated responsibilities for a full picture of organisational senior management duties and responsibilities.
Create Certification Regime
Blueprint’s SMCR Manager allows organisations to create a flag for specific senior managers for inclusion in the certification regime. As part of the self-declaration process, senior managers answer fitness and propriety questionnaires, review and sign-off on their job description, role, title and assigned FCA Significant Harm Functions (SHFs).
Automated workflows ensure that flagged managers receive and sign off on the appropriate paperwork. The automatic creation and preservation of a full audit trail for all SMCR activities provides for historical or “As Of” reporting of SHF mappings at any point in time.
Blueprint SMCR Manager Simplifies and Facilitates Ongoing Compliance
Initially implemented in 2016, SMCR requirements continue to escalate. The FCA plans to expand the rules to cover more financial services firms. In tandem with the Market Abuse Regulation, which took effect in July 2016, SMCR significantly increases the compliance burden on firms operating within the UK. With strict penalties, organisations must maximise their compliance systems to ensure that relevant data and changes don’t slip through the cracks.
Automation with state-of-the-art and continually updated tools ensures ongoing compliance and a lower burden on legal and compliance teams. Blueprint’s fully integrated SMCR Manager draws data already in the system and captures data gathered for SMCR purposes for ongoing compliance and analysis purposes. Trust Blueprint to manage the SMCR compliance process with unparalleled ease, consistency and diligence.