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Control Your Conflicts: Strategies for Transparency & Integrity
WEBINARBeyond Compliance: Elevating Governance and Managing Risks Effectively
WEBINARNavigating Disruption: Building Operational Resilience in Today's World
WEBINARBeyond the Checklist: Unveiling the True Essence of Consumer Duty
WhitepaperOperational Resilience: Adapt, Respond & Recover
WhitepaperBest Practice in Third Party Risk Management
WhitepaperGuide to the FCA’s Strategy
WhitepaperSM&CR: Enhancing Ethics, Accountability & Culture
The SM&CR review was announced as part of the Edinburgh reforms towards the end of 2022, with HM Treasury indicating that “ some stakeholders have raised concerns about their experiences of specific aspects of the regime .” Consequently, the government is assessing...
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Conflicts of interest is a subject matter that should be relatively easy to understand and as such, straightforward when it comes to compliance. Why then do we hear of senior managers who have failed to declare a potential conflict or to recuse themselves from related...
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UK Government issued a consultation paper last year setting out its proposals to replicate the Senior Managers & Certification Regime (SM&CR) for Financial Market Infrastructures (FMIs), who are not authorised firms. Here we look at the outcome of that consultation....
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One of the fundamental obligations applicable to all regulated firms is the need to implement appropriate processes to manage risks. One such risk is that of providing unsuitable advice to consumers. This area has been a regulatory hot topic for some time. Remember the...
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The Senior Managers & Certification Regime (SM&CR) was first introduced in 2016 for banks and then phased in until it was finally extended to include the remaining regulated firms at the end of 2019. SM&CR aims to encourage greater accountability within firms whilst...
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The Senior Managers & Certification Regime (SM&CR) for insurers took effect in December 2018. As part of the Solvency II regime, insurers were already subject to the Senior Insurance Managers Regime (SIMR) introduced in 2016. Despite that, there were some new...
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Since the financial crisis of 2008 regulators worldwide have been introducing reforms to improve individual accountability within firms. Regulators were criticised for their lack of action and not preventing the crisis. Further criticism was aimed at firms’ failings...
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This was the view of the Payment Systems Regulator (PSR) back in 2015 when the PSR was still relatively new. Six years later and it’s fair to say that payments systems are even more critical today. It’s a message echoed by the Bank of England (BoE) and evidenced by the...
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HM Treasury issued a consultation earlier in July. The proposals signal HMT’s intention to extend the Senior Managers & Certification Regime (SM&CR) to include Financial Market Infrastructures (FMIs). Interested parties should submit their responses by 22 October 2021....
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With the publication of final policy statements there is a clear message that firms must look externally at third party relationships as part of their Operational Resilience framework. The requirements are designed to promote stronger and more effective governance of...
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Since the introduction of the Senior Managers and Certification Regime (SM&CR), it has been interesting to see how and where firms have allocated most of their resources to comply with the new rules. Implementation tends to follow one of two strategic approaches:...
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In light of the turbulence caused by the Covid-19 pandemic, SMCR may have been pushed down the priority list for most firms for now. The disruption has however given rise to a number of practical and compliance challenges which have a direct and imminent impact on...
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