Senior Managers & Certification Regime Training
Firms have an obligation to train impacted staff members
With the introduction of the Senior Managers & Certification Regime (SMCR), firms have an obligation to train impacted staff members, including Senior Managers who have a statutory “duty of responsibility” to take reasonable steps to prevent, stop and remedy regulatory breaches in the areas of the firm for which they are responsible.
The Brief
We have been engaged by many clients to help develop best practice content and deliver subsequent training, with specific focus on building awareness amongst Board and Executive Committee members of the regulatory expectations and how they can best evidence their reasonable steps when discharging their accountabilities.
In addition, each firm received high quality training content and ‘train-the-trainer’ workshops to enable them to deliver their own in-house SMCR training for Certification staff on a repeatable basis without continued reliance on external experts.
The Solution
Our team initially worked with each firm to quickly tailor our predefined BCS reasonable steps framework. This included identifying which current information repositories captured evidence and how the framework components applied to each Senior Manager given that they vary across the Lines of Defence and for individuals within governing functions.
We leveraged existing high-quality training content, which has been proven and refined with many banking and insurance firms who have already gone live, to tailor the content for each firm’s Senior Managers and Certification staff. The training covered the fundamentals of the regime, how it impacted them individually and the tailored BCS reasonable steps framework. It was all brought to life through real industry case studies and manufactured scenarios to stress test specific areas of concern, such as where accountabilities cut across organisational boundaries.
The team delivered training to groups of Senior Managers, primarily divided between Board and Executive Committee members. We helped them individually understand the regime and how to adopt the BCS reasonable steps framework to self-assess the robustness of their own evidence and to self-identify any gaps or blind spots in relation to their accountabilities.
In addition, we delivered training to key Certification staff and ‘train-the-trainer’ workshops with HR and Compliance teams to equip them with required information to deliver impactful training in the future, such as accurate answers to technical questions and industry examples.
The Results
The training content and impactful delivery helped many individuals better understand the specifics of the regime and how it applies to them personally, giving both the right level of comfort and the need to take it seriously.
The BCS reasonable steps framework provided a proven structure to breakdown reasonable steps logically and in a manner that enables Senior Managers to translate them into everyday business language and relate them to existing governance, systems and controls. Supported by impactful training and scenario testing, they were able to quickly self-assess their part of the business and identify areas requiring remediation.
The training content can now be leveraged by firms on a repeatable basis and for a long period of time under the regime, removing ongoing reliance on external experts.
