Help maintain accountability within your firm and manage SMCR responsibilities more efficiently.

Since the announcement in December 2022 of the Edinburgh Reforms, accountability, company culture, and governance are three essential elements that regulated firms must strictly monitor. The Senior Managers and Certification Regime (SMCR) is a big part of this and provides a framework for firms to do so throughout their organisation. In practice, this means that firms must regularly assess their Senior Managers and employees with other roles that could “cause significant harm to the firm or its customers” for their suitability, monitor compliance and good conduct across all staff, and be able to demonstrate these activities to the regulator.

What are the SMCR requirements?

SMCR Conduct Rules

• SC1: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively.
• SC2: You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system.
• SC3: You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively.
• SC4: You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice.

Digital tools like ComplyPortal’s SM&CR module help firms to abide by these above conduct rules and allocate each of the FCA-prescribed senior management responsibilities to a Senior Manager. Senior Management Functions (SMFs) can easily be assigned to Senior Managers, allowing them to view their assigned responsibilities. ComplyPortal provides a systematic method to track assignment and transfer of individual accountability to better maintain oversight and ensure their firms remain accountable and properly governed.

Who is it for: Compliance Officers and Senior Managers

Key features:

• Create thorough audit trails to demonstrate compliance
• Assign Senior Managers to SMF responsibilities
• Manage responsibilities for Senior Managers and Certified Individuals
• Transfer responsibilities to new individuals
• Provide Senior Managers with oversight and the ability to monitor their area of responsibility
• Upload and attach all relevant documents such as SoR to each Senior Manager
• Create and manage committees
• Assign and schedule out all relevant SM&CR Attestations via our Attestations Module

How it benefits you:

Using a compliance management tool like the SM&CR module simplifies processes of accountability within regulated firms. The ability to assign Senior Management Function (SMF) responsibilities to individuals, attach documents such as SoC to each Senior Manager, and transfer responsibilities to new individuals provides firms with a clear record of accountability and governance. Additionally, ComplyPortal also offers functionality for a Fitness and Propriety questionnaire to support regular assessments of whether or not relevant Senior Managers and Certified Individuals are “fit and proper” for their roles. All available actions produce clear audit trails to demonstrate approvals and responsibilities to the regulator, bringing welcome ease to Senior Managers juggling multiple responsibilities.

The Compliance Perspective:

“While compliance management is often a complex undertaking, managing SMCR compliance does not have to be. Streamlining and centralising processes such as SMF and prescribed responsibilities allocations through dedicated software—instead of, for example, using assorted spreadsheets shared with staff—offers welcome simplicity and security for compliance officers.

This is especially valuable in the new world of work as companies increasingly adopt flexible, hybrid, or fully remote-working practices where reporting lines and responsibilities can become blurred. Staff can be kept up to date with current allocations and their approvals and acceptances can be tracked and recorded regardless of where they work.” – Simon Chapman, Director at Complyport

Find out more about our SM&CR module and the rest of the ComplyPortal platform at: https://complyportal.uk/modules

About ComplyPortal:

First developed in 2011 by compliance professionals for compliance officers, ComplyPortal offers workflow, automation, and several modules to help firms with control and regulatory compliance monitoring.

ComplyPortal simplifies financial services regulatory compliance management on an easy-to-use cloud-based comprehensive compliance platform. It enables compliance officers, risk officers and senior management to keep track of their firm’s regulatory responsibilities and workflows. Our platform includes the following modules, among others:

• Monitoring: a year-round schedule pre-populated with monitoring questionnaires to ease compliance processes.
• Approvals: authorise request and keep track of workflows
• Registers: lists controlled by the Compliance officer, but easy for staff to view.
• Risk: map and control risk areas to effectively identify and manage risk for your firm.
• Training: access our LMS platform for all Compliance and Governance Training

Help maintain accountability within your firm and manage SMCR responsibilities more efficiently.

Accountability, company culture, and governance are three essential elements that regulated firms must monitor. The Senior Managers and Certification Regime (SMCR) provides a framework for firms to do so throughout their organisation, from Senior Managers themselves to general members of staff. In practice, this means that firms must regularly assess their Senior Managers and employees with other roles that could “cause significant harm to the firm or its customers” for their suitability, monitor compliance and good conduct across all staff, and be able to demonstrate these activities to the regulator.

Digital tools like ComplyPortal’s SM&CR module help firms allocate each of the FCA-prescribed senior management responsibilities to a Senior Manager. Senior Management Functions (SMFs) can easily be assigned to Senior Managers to view and accept their assigned responsibilities. ComplyPortal provides a systematic method to track assignment and transfer of individual accountability to better maintain oversight and ensure their firms remain accountable and properly governed.

Who is it for: Compliance Officers and Senior Managers

Key features:

• Create thorough audit trails to demonstrate compliance
• Assign Senior Managers to SMF responsibilities
• Manage responsibilities for Senior Managers and Certified Individuals
• Transfer responsibilities to new individuals
• Provide Senior Managers with oversight and ability to monitor their area of responsibility

How it benefits you:

Using a compliance management tool like the SM&CR module simplifies processes of accountability within regulated firms. The ability to assign Senior Management Function (SMF) responsibilities to individuals who can then approve and accept these provides firms with clear record of accountability and governance. Additionally, the module also offers functionality for a Fitness and Propriety questionnaire to support regular assessments of whether or not relevant Senior Managers and Certified Individuals are “fit and proper” for their roles. All available actions produce clear audit trails to demonstrate approvals and responsibilities to the regulator, bringing welcome ease to Senior Managers juggling multiple responsibilities.

The Compliance Perspective:

Find out more about our SM&CR module and the rest of the ComplyPortal platform at: https://complyportal.uk/modules

About ComplyPortal:

First developed in 2011 by compliance professionals for compliance officers, ComplyPortal offers workflow, automation, and several modules to help firms with control and regulatory compliance monitoring.

ComplyPortal simplifies financial services regulatory compliance management on an easy-to-use cloud-based comprehensive compliance platform. It enables compliance officers, risk officers and senior management to keep track of their firm’s regulatory responsibilities and workflows. Our platform includes the following modules, among others:

• Monitoring: a year-round schedule pre-populated with monitoring questionnaires to ease compliance processes.
• Registers: lists controlled by the Compliance officer, but easy for staff to view.
• Risk: map and control risk areas to effectively identify and manage risk for your firm.
• eKYC solution: perform comprehensive searches, including client identity verification, document authenticity, and more for a comprehensive KYC and AML approach

A step-by-step guide to getting colleagues ‘on side’ when proposing or making a new regtech investment

While a firm’s compliance is handled by dedicated staff, the impacts and actions of complying with regulations reach across the whole organisation. Therefore, when making changes to your compliance processes – for example, investing in regtech – there are several stakeholders to consider, and securing their buy-in is important. If you are looking to modernise compliance processes and have colleagues yet to be convinced, this step-by-step-guide is for you.

1. Communication is Key

A key element of securing stakeholder buy-in is the ability to demonstrate that the change you want to implement will help your organisation as a whole. Consider the approach taken by Steve Williams, Senior VP, Regulatory Compliance at Teleperformance BPO. In our webinar, Driving the Rise of Modern Compliance, he told us:

“We did a series of sessions with the people in operations who would be inputting to the system and providing us with info. The purpose of that was to persuade them and influence them that this is going to improve the efficiency of what we did and therefore make it less onerous for them.”

Reach out to colleagues outside of your compliance team who are impacted by your firm’s compliance activities and make sure that they understand how your chosen regtech investment can directly or indirectly help them, too.

2. Demonstrate Practical Value

While communication is important, it should be paired with action. This dual approach is an even more effective way to demonstrate the benefits of any investment in new software or change in operations.

On this topic, Steve observed:

“If you can get their buy in in terms of making sure that they understand that this [software investment] is going to help them, then they’re going to use the system.”

This matters because if the regtech you want to implement is useful to multiple areas of your business, it becomes a more interesting and valuable investment. Just remember to reassure your colleagues that your proposed software is not intended to replace necessary human activities and expertise, but rather to enhance operations and client experiences.

3. Convince Senior Staff

Once you have the support of your colleagues, it is time to ‘seal the deal’ with more senior stakeholders – think Board-level or C-suite. If you do not possess the power to sign off on new investments, it is important to secure the approval of those that do, and transparency and accountability with your Board are important practices.

Evidence the value of your proposed regtech investment by sharing your communications and practical engagement with both the compliance team and other areas of the organisation. Don’t forget external stakeholders, too – your chosen regtech should be able to bring benefits to your clients as well as to your staff – for example, through digitalising time-consuming processes to give staff more free time for more hands-on and client-facing compliance tasks. The more benefits you can demonstrate, the more appealing and useful your proposed regtech will seem.

1. How ComplyPortal Can Help

Visit https://complyportal.uk/modules/ to find out how our straightforward, comprehensive compliance technology solution can help you and your organisation. You can also book a software demo or talk to one of our expert advisors to discuss how our compliance technology can meet your and your organisation’s needs.

About ComplyPortal – Compliance software since 2011:

First developed in 2011 by compliance professionals for compliance officers, ComplyPortal offers workflow, automation, and several modules to help firms with control and regulatory compliance monitoring.

ComplyPortal simplifies financial services regulatory compliance management on an easy-to-use cloud-based comprehensive compliance platform. It enables compliance officers, risk officers and senior management to keep track of their firm’s regulatory responsibilities and workflows. Our platform includes the following modules, among others:

• Monitoring: a year-round schedule pre-populated with monitoring questionnaires to ease compliance processes.
• Registers: lists controlled by the Compliance officer, but easy for staff to view.
• Risk: map and control risk areas to effectively identify and manage risk for your firm.
• eKYC system: perform comprehensive searches, including client identity verification, document authenticity, and more for a comprehensive KYC and AML approach

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