We all know that the Senior Managers and Certification Regime (SM&CR) is complex, with multiple elements to understand and multiple tasks that businesses need to complete in order to evidence compliance. Understanding the requirements and implications of the regime, and then forming a strategy and process for compliance takes a significant investment of time and resources.
It’s no wonder that busy financial services firms look outside to third-party experts to help them become – and remain – compliant. However, the landscape can be confusing, with multiple providers claiming to provide a ‘complete’ compliance solution.
Broadly speaking, these solutions providers fall into two camps; consultants, and technology solution providers. Each type of supplier offers its customers fundamentally different services, but they all have the same goal – to help their customers achieve and evidence SM&CR compliance.
Compliance consultancies – whether specialist SM&CR consultancies or more generalist firms delivering SM&CR support as part of a wider compliance offering – provide support, training and guidance on SM&CR implementation and ongoing compliance. Solutions and services vary, but typically cover:
- Assistance in determining SM&CR firm status
- Guidance on setup for record-keeping
- Training on SM&CR components
- Process and workflow advice
- Ongoing compliance support and audit.
Usually, the goal of a compliance consultancy is to provide firms with the knowledge and expertise required to effectively manage their own staff under the SM&CR – but the actual implementation and ongoing management is left to the firm to manage.
Compliance management solutions
Compliance software and solutions, such as Corterum, are a fundamentally different proposition. They provide an actual framework around which SM&CR compliance can be built and evidenced, typically incorporating:
- Record keeping
- Audit trail
- Process management
- Generation of FCA-mandated reports, statements and certificates
- Management of changes in staff circumstances
All of these functions can be managed without a compliance software solution, through tools such as Excel, but such manual solutions require a significant investment in time and resources to manage – time and money that solutions like Corterum are designed to save.
The framework for compliance
There’s no doubt that whatever route firms choose to use to manage their SM&CR compliance – some form of record keeping is required. The FCA’s rules (SYSC 2.2.1R & SYSC 22.9.1R) require ‘orderly records’ to be kept for reference requests and a record of Senior Manager responsibilities for at least six years.
Compliance consultants can help you with what to record to evidence SM&CR compliance, but not how or where to record it. By their very nature, compliance audits are largely retrospective in nature. Unfortunately, they do little or nothing in terms of assisting with pro-actively monitoring compliance – the real secret to assimilating SM&CR compliance into ‘business as usual’ processes.
A solution like Corterum provides the framework to keep you on track 24/7/365 –between visits from your compliance consultants. The two can work incredibly effectively hand in hand, but one should not be mistaken as obviating the need for the other.
If you’re looking for a robust, complete and cost-effective SM&CR compliance solution, either to support the work you’re doing with a consultancy, or your own internal SM&CR approach, why not drop us a line to see how we could help?