A nervous disposition
With the Senior Managers and Certification Regime (SMCR) due to be extended to all regulated financial services firms in six months’ time (9 December 2019), we reflect on three key learning points from the regime which has already been in place for banks, building societies, credit unions and PRA- designated investment firms since March 2016.
The FCA has been determined to drive cultural change in financial services for some years now. Since the Parliamentary Commission on Banking Standards published their seminal report ‘Changing banking for good’ in 2013 there has been a concerted drive to improve the culture of financial services, to avoid future financial scandals, and ensure accountability and responsibility for risk management, compliance and wrongdoing from the top down.
In the not too distant past, a directorship in a bank, insurance company or financial services firm was seen as a lucrative and career-defining role. Many directors built a career out of having a portfolio of Board appointments, which involved a significant degree of responsibility to the organisation, but, in many circumstances, little personal regulatory oversight.
7 March 2017 marked the first anniversary of the implementation of the Senior Managers and Certification Regime. However, rather than coming with cake and candles, this birthday was celebrated with the introduction of the next phase of the regime.
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