Where are my biggest implementation risks? What might I get wrong?
With any new regulation, there are risks that compliance steps will not be properly taken and the organisation or persons responsible will be penalised. It’s important, then, to understand what could go wrong. The first risk is a lack of comprehensive understanding of what needs to be implemented, where, and by whom. If responsibilities are being delegated, it’s imperative to know who will be accountable for those, that they’ve been understood, and that the FCA’s expectations are still going to be met.
Another risk comes with embedding an SMCR workflow into your governance frameworks and processes. You must develop a Fit & Proper assessment framework, determine who should be responsible for coordinating the process and assess potential HR implications. These will need to be embedded organisation-wide, so there’s the challenge of not only performing the right duties but keeping accurate audits for every employee.
Beyond demonstrating compliance, there’s a risk that the conduct responsibilities will not be met if your firm, or any employees fails to properly interpret what’s required of them.
Can I be compliant by implementing a few new templates and input from a few people part-time?
SMCR compliance needs to be met and demonstrated effectively, and the responsibilities your firm must address should not be taken lightly. Haphazard, light-touch approaches will not impress the FCA if something goes awry. Still, this can be managed efficiently.
A suitable GRC solution such as SureCloud’s SMCR Manager helps you to understand what’s required of your firm and each of your staff depending on their role and specific duties. SureCloud’s platform helps you to create a meaningful workflow for assessment but also for certification and authorisation widely across the company.
With SureCloud’s SMCR Management solution, you can create and manage a centralised register for FCA prescribed roles and responsibilities and the employee’s that hold them; past and present. It also helps you clearly demonstrate compliance by providing FCA templated outputs containing suitable and pertinent information – and provides all of this through one single platform that can be accessed through the cloud.
Watch our Latest Webinar
SureCloud’s Product Director, Alex Brown, explains how SureCloud’s solution can strengthen and streamline your process. As well as help you demonstrate your SMCR compliance efforts in a joint webinar with Baringa’s Senior Manager, Edouard Bassil. For more insight, watch the webinar here.
Check out ‘SMCR Blog 1: The challenges you may face with SMCR’ where we looked at how SMCR may effect your business and what reasonable steps you need to take to ensure you are prepared.