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Guest writer, Stephen Humphreys, Senior Manager at Baringa

This blog post is written by our partners, Baringa. Baringa Partners is a diverse management consultancy with an award-winning culture. Read up on their thoughts behind implementing technology into your SMCR programme.


Technology can make a big difference with SMCR implementation. As firms make the required changes to their risk and control environment, technology is the obvious place to turn. As you look at your own options, here are some key questions worth considering:

  • How will I meet the ‘time machine’ requirements of SMCR and be able to say who was responsible for what at any point in time, post-implementation?
  • Will I have an audit-able date stamp for when responsibilities are changed or accepted by SMFs? Can I show that we remained compliant when exercising rights under the 12-week (Senior Manager) or four-week rule (Certification)?
  • How will I gather and store the information required to assess my SMFs and Certification population as Fit and Proper?
  • How do I know that all my relevant people have completed conduct rules training? Can I demonstrate that the training was appropriately tailored to their role?
  • Where will I hold breach information so that it remains appropriately secure but also accessible for regulatory reporting and references?


Here’s a snapshot of how you can use technology to help implement SMCR:


1. Responsibilities Maps and Statements of Responsibility (SORs)

Technology platforms can act as a useful tool in tracking changes and the ‘version history’ of Responsibilities Maps and SORs. They can also automate the creation and population of SORs and record where responsibility has been delegated.


2. Training and Competence / Certification

Technology can deliver workflow tools that support Certification, including:

  • Recruitment and on-boarding
  • Fit and Proper attestations
  • Hard employer checks
  • Conduct Rule breaches and findings
  • Performance management
  • Proof of certification


3. Learning Management

Technology can be used as a means of delivering and tracking the conduct training.


See you next week for our seventh instalment in the blog series: “How to manage your SMCR compliance programme effectively”



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