Senior Managers & Certification Regime Operating Model Design and Implementation
Senior Managers & Certification Regime (SMCR) implementation date – 9th December 2019
With the implementation date of the Senior Managers & Certification Regime (SMCR) confirmed for 9th December 2019, a number of asset management clients have engaged us to perform a regulatory gap analysis and lead the design and implementation of the new operating model required to support their ongoing compliance with the regime.
The Brief
The primary aim of each engagement was to provide regulatory advice and best practice guidance to ensure the regime was implemented in the most compliant and proportionate manner for the firm. This included translating the regulatory rules into practical solutions and approaches, expediting delivery timelines by leveraging our predefined SMCR operational framework and by removing the need for long running and sizeable delivery programmes.
The Solution
We worked with the client teams to understand the current infrastructure which could be leveraged to support the regime in business as usual. This included reviewing the current application of the Approved Persons Regime to understand how best to apply SMCR to current management and governance structures, in addition to identifying existing policies, procedures and processes that could be leveraged to support the regime.
Following the initial analysis phase, we helped drive the implementation forward by delivering new or enhanced processes, policies and procedures, regulatory artefacts and key supporting documentation to enable each client to meet their regulatory obligations under SMCR.
These designs and solutions were based on predefined tools and templates developed by us which were quickly tailored to each client’s requirements. Once the operating model was designed and agreed, we then provided the necessary support and knowledge transfer to enable them to mobilise the business as usual operations and to start managing organisational change in line with SMCR requirements.
The Results
Our advice and leadership helped each client to identify and agree the most appropriate allocation of Senior Managers and associated responsibilities, which reflected ultimate accountability and true decision making.
In addition, they were able to quickly establish an effective and proportionate business as usual operating model that achieved full compliance with the regime and enabled them to more effectively identify, manage and control organisational change.
Ultimately, our predefined SMCR solutions helped them to expedite delivery timelines and vastly reduced cost and effort.
