GRACE to manage Senior Management Certification Regime (SM&CR)

Manage Senior Management Certification Regime

Following the 2008 financial crisis and subsequent review of the financial services industry, parliament sought to replace the UK Approved Persons Regime (APER) with a regime that was more focused on firms’ senior managers and individual responsibility. This resulted in the creation of a new Senior Managers and Certification Regime (SMCR).

GRACE provides an easy way of establishing, management of various roles and responsibilities, getting senior management to attest about them and keep track of their obligations

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Senior Management Certification Regime

Following the 2008 financial crisis and subsequent review of the financial services industry, parliament sought to replace the UK Approved Persons Regime (APER) with a regime that was more focused on firms’ senior managers and individual responsibility. This resulted in the creation of a new Senior Managers and Certification Regime (SMCR).

The SMCR’s overarching aim is to reduce harm to consumers and to strengthen market integrity. This is achieved by raising the standards of conduct for everyone who works in financial services, and by making senior people in firms more responsible and accountable for their conduct, actions and competence. The regime shifts the responsibility of activities within a firm onto senior managers and brings into scope non-executive directors.

How Will the Regime Apply to Different Firms?

For solo-regulated firms, the FCA took a proportionate approach to implementation to reflect the different risks, impact and complexity of firms subject to the extension. Under the FCA’s regime, firms are categorised depending on their size and profile into Core, Enhanced or Limited Scope firms.

Core Regime Firms – This will be the majority of firms, to which the standard set of ‘core requirements’ will apply

Enhanced Regime Firms – These are the largest and most complex firms, to which extra requirements will apply

Limited Regime Firms – These firms will be subject to fewer requirements than Core Regime Firms

The SMCR sets following key expectations

Reserved for the most senior individuals (‘Senior Managers’) who perform key roles (‘Senior Management Functions’ or ‘SMF’) it is required to be approved by the FCA

Statements of Responsibility (SoR) – Every SMF requires a document their responsibilities and accountability

Prescribed Responsibilities – List of prescribed responsibilities which must each be allocated to an appropriate Senior Manager

Duty of Responsibility – Reasonable steps to prevent a regulatory breach occurring

Responsibility Maps – Enhanced firms must prepare and maintain a single document of firm’s management and governance process

Handover Procedures – Enhanced firms must ensure staff with SMF role have all information and materials needed to do their job effectively. Firms must have policies explaining how it complies.

Overall Responsibility – Enhanced firms need to ensure that every activity, business area and management function has a Senior Manager with overall responsibility for it

The Certification Regime (CR) – Employees who are not Senior Managers but whose job can cause significant harm to the firm or its customers must undergo Annual certification. Responsibility for the CR must be allocated to a Senior Manager

The Conduct Rules include Individual Conduct Rules for all employees (except ancillary staff) and Senior Manager Conduct Rules for Senior Managers.

GRACE Can help you Manage this process efficiently

GRACE web based / tablet enabled, SMCR system offers you with collaborative tool which encompasses the Compliance department, Senior Management and Staff to establish the process for Policies, Senior Management Roles and Responsibilities definition, periodic reporting and keep track of any breach of responsibilities.

Centralized issue management helps you manage assignment, recording notes and issue closure.

GRACE offers Online Attestation Templates setup to ensure all the roles and responsibilities are clearly set up and sent to the respective people for their online attestation.

Attestation dashboard can keep track of status of attestation and ensure pending items are followed up.

GRACE Training allows setting up of customized training for the staff that can enable them to understand their roles and responsibilities and work in accordance to the code of conduct expected.

When there is a Staff turnover, GRACE makes it easy to onboard the new person to their roles and responsibilities using the online structured process.

Firms must report disciplinary actions taken due to a breach of the conduct rules to the FCA. This must be completed within seven days for Senior Managers, and on an annual basis for all other employees. GRACE allows keeping track of breach of conduct cases.

GRACE becomes the proof of compliance for FCA regulatory examination

GRACE SMCR Management

Made Easy with an Integrated Approach

Policies and Procedures Management

  • GRACE helps set up and manage the Policies and Procedures of the organization. It allows the policy and procedure management group to setup new policies, manage the changes to policies, review them among the peer group, record peer group comments and create the final version of the document, and release it to staff when complete. It keeps track of all the versions in the system

Online Periodic Reporting

  • GRACE can help set up the periodic reporting calendar and assign the reporting function to the respective owner for them to report online.
  • Reporting templates can be set up that can be used to ask for specific information for that function. Email reminders can be sent to remind function owners to report on their responsibilities
  • Issues in doing the functions can also be reported and tracked. Reports Dashboard can help track and monitor the reporting

Set up and Manage Organizational Structure, Roles and Responsibilities

  • GRACE can help set up and record the Organization Structure, the their role and responsibility definitions and staff that are assigned on those roles.
  • It also helps track their attestation status of their documents of their accepting the roles and responsibilities as per the role definitions

Setup and manage Training

  • GRACE helps manage the Training calendar by setting up the dates on which training would be conducted, along with information on the Training organization and documents that can be shared with the staff. GRACE can help add and manage staff that need to be included into the training. User Groups can be created an groups of users can be assigned training courses.GRACE will send out e-mail alerts to users on the dates of training and send them reminders based on their training status.
  • La Meer can also help users set up Customized Training courseware on GRACE that can be periodically change to reflect the business and role changes and allows the staff to be trained online.
  • The Training dashboard provides graphical view of all training sessions and the progress and scores of individual users and status of completion

Manage Attestations

  • GRACE can help set up attestation templates that are needed to signed by senior management to fulfil their roles and responsibilities.It can set up one time / periodic attestations for all the staff , send them e-mails to alert them of their requirement to attest and allow them to attest online.
  • For new comers / change of personnel from one role to another, the system can send them the new attestation set and allow them to attest online. GRACE will send reminders to staff. It provides the books and records to show proof of attestation.

The Great Value You Get from Using GRACE SM&CR

Organized, Efficient Oversight across the Organization

Manage every aspect of SM&CR Comprehensively and Effectively

Helps you build your Senior Management & Certification program in an effective manner to address the regulations comprehensively

Management reports on-line

Web based access, anytime anywhere, means no need for reports to be generated in various departments for presentation to senior management. Effort, costs, and time can be saved.

Early awareness reduces non-compliance

Online attestation for defined roles and responsibilities enables staff to be aware of their roles and ensures they can adhere to them.

Regulatory examinations can be handled with confidence

GRACE becomes live proof of compliance in the organization and saves an enormous amount of money in data gathering and report creation process for regulatory audits and examinations.

Customizable content for Organizational Process

By Creating and customizing the course ware to the organization’s processes training can be delivered at all levels to ensure their roles and responsibilities are well understood

Customized Training for your particular business needs can be quickly deployed

Customization of your training to meet the business requirements can be done quickly to enable you to adapt to new regulations or business changes and deliver it to your team on a regular basis

Organization Ownership of Data

Organizations suffer when key risk and compliance staff leaves. The information is scattered if maintained solely by individuals and are lying on disks in various forms. GRACE becomes the single central repository of documents, data and processes enabling continuity even when key people leave the organization

Visibility and Transparency through Powerful Dashboard

The Dashboard view provides all status at a glance to ensure all staff activities related to SM&CR are well understood and adhered to

Culture of Compliance gets institutionalized

With a business as usual process through the enterprise, a culture of compliance becomes institutionalized across the organization.

Establish Accountability

By making policies and procedures, roles and responsibilities, attestation and training thru a transparent process, accountability to ensure compliance can be established

Enormous Cost Savings

Enormous costs savings from having all the activities online

Avoid Excel Based Monitoring

Manage and keep track of people and their training processes in Excel sheets can be avoided

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