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Jonathan Max

SMCR - How prepared are asset managers?

How prepared are Asset Managers for SMCR?  

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Andy Milner
2 hours ago, Julia Kirkland said:

 Culture change is required and some appear to be ignoring this.


@Julia Kirkland - I agree with this.  I wonder if many companies are focusing purely on the process and technical aspects of implementing the regulations without looking at the broader cultural perspective - perhaps ignorant to the cultural change required, or assuming implementing SMCR will drive the change in culture without a broader effort.

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Pierre-Yves Rahari

On the topic of governance in Funds: I did catch-up with Margaret Cullen earlier this week, the founder of the CIFDI, a programme set up to train aspiring Investment Funds Directors (https://www.cifdi.org/about-us). Seemingly, similar programs are setting up in the industry, indicating that Firms are preparing to meet the stronger governance requirement called for, not only in the UK, but across Europe in general ...


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Andy Milner

@Stuart Bull - with 278 days to go until the extension comes into effect, I wouldn't be surprised if some Asset Managers were starting to think the same.


Possibly some have been waiting for change resource freed up from Brexit preparations to move on to this?


The FCA have also recently released a video of banking leaders giving advice based on their implementations.



The Senior Managers and Certification Regime (SM&CR) replaces the Approved Persons Regime, changing how people working in financial services are regulated.


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Stuart Bull

We are seeing firms really starting to take note of what is required. This is possibly as a result of listening to peers from firms already under SM&CR.

Our experience of supporting clients within the banking sector highlighted to us that many would admit they would, with hindsight, have allowed more time and resource to ensure their projects were completed with plenty of time before the deadline. 

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Jonathan Max

Thanks @Andrew Pullman. It was interesting to hear the legal perspective from the panel of both Employment and Regulatory lawyers as far as some of the practical steps firms need to consider through the extension of the regime.


Clearly there much work to do in preparing Responsibility Maps, Statement of Responsibilities and Prescribed Responsibilities together with the associated employment law aspects from updating contracts to the supporting policies etc. 


Really good article from the FT which highlights what is needed to support the cultural change which The FCA is driving through the regime. As you say, HR and Compliance working together and supported by legal support will be essential. 


As cited in the article, information and reporting will need to underpin in ensuring a robust and BAU process; @Caroline Sheldon - is this consistent to what you are hearing from your clients?


"This should be backed up by robust employee record-keeping processes and technology, as well as procedures to manage the impact of breaches and suspected breaches"





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Andrew Pullman

Thanks @Jonathan MaxI sat on the panel at the recent City HR  Assocaition seminar on SMCR where the FCA outlined the next phase. Key issues for asset managers are to start engaging and preparing for the upcoming introduction of the SMCR regime in December 2019.


it is vital that Compliance and HR work closely together.


As an HR consultancy we are working with firms to get ready #PeopleRiskSolutions and are also are developing a RegTech tool to help manage the Fit Proper and Competence annual certification process #PeopleClear SMCR.

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Andy Milner

Thanks @Jonathan Max - will be interesting to hear if the mood there is inline with our pulse poll on the subject (i.e. currently not overwhelmingly positive!)

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Jonathan Max

Looking forward to attending CITY HR event tomorrow aimed at firms embarking on SMCR and the latest thinking and learnings from organisations already in scope.


Speakers are from the FCA, leading Law firms and industry practitioners including one of our partner firms People Risk Solutions @Andrew Pullman


@Stuart Bull, @Lydia Francis it will be interesting to see how prepared firms are....I will share key findings to the community



Assessing your readiness for the SMCR extension Aimed at firms embarking on SMCR, or those in scope who would like latest thinking, this programme will: Provide an SMCR overview with expert insight direct...


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Luuk Jacobs

Great timeline and I almost already can imagine where the bottleneck for this is going to be ..... the MI. The investment management industry is still getting to grips with good risk data and reporting due to multiple legacy systems and lack of well implemented risk systems. Certification of applicable staff seems a long time away ie Q4 2020 but the certification is based on the last years data so the certified person needs to be able to attest over the past 12 months ie Q4 2019 to Q3 2020 ...... a challenge ahead and only 7 months to go.

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Andy Milner

Here's a useful timeline from FSTP on key milestones:





The scope of the Senior Managers and Certification Regime is huge and the impact on the financial services industry can’t be under estimated. You just have to speak to the firms already under…


@Stuart Bull @Lydia Francis

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Andy Milner

There's been so much experience of this already across Banking - has anyone else in the community got any experience of how the role out was at this stage in Banking?

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Luuk Jacobs

It seems there is still a lot to be clarified in businesses when it comes to SMCR. Having spoken to some senior management in general and some that would be one of these Senior Management positions that need certification, there still seems to be a lack of understanding as to what the consequences are. Equally with this coming into play as of end September, it should be all over the recruitment agenda to ensure that people recruited in these positions (with often lead times of 3-6 months) understand the risk associated to the business they will be leading

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Andy Milner

Good to see some (positive) initial responses to this!


@Luuk Jacobs @Rob Carter @Colin Ng @Pierre-Yves Rahari  - would be interesting to get your views from your client work.

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Jonathan Max

With the scope of SMCR extending to the Asset Management Industry we wanted to get some initial views on how prepared firms are for the required regulatory changes

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