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
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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:

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
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