Statements of Responsibilities are a key element of the SM&CR and a key focus of the FCA. If you bear these basic rules in mind, you can’t go far wrong…
The top 10 things you need to know about Statements of Responsibilities…
- If you are a Senior Manager, YOU are responsible for your Statement of Responsibilities, along with your firm – don’t think that it’s someone else’s job.
- A Statement of Responsibilities is a single document which sets out a Senior Manager’s responsibilities. It should NOT describe HOW those responsibilities are carried out (it is NOT a job description).
- Every Senior Manager must have their own Statement of Responsibilities – don’t combine Statements of Responsibilities for multiple Senior Managers.
- An individual must have a separate Statement of Responsibilities for each company for which he/she acts as a Senior Manager.
- When lined up together, the Statements of Responsibilities for all Senior Managers within a firm should show no gaps in the allocation of senior manager responsibilities.
- Statements of Responsibilities should be practical and useable; succinct, clear and easy to understand; avoid unnecessary detail; and be consistent across the firm.
- Statements of Responsibilities should make clear whether a Senior Management function is shared or divided (e.g. as part of a job-share or a handover of responsibilities).
- Statements of Responsibilities must be kept up-to-date – the FCA must be provided with a revised Statement of Responsibilities if there has been any “significant change” in responsibilities.
- Firms must have a complete set of CURRENT and PAST Statements of Responsibilities for all Senior Managers – they are an important part of the firm’s regulatory record keeping obligations.
- The Statement of Responsibilities for a non-executive director may be less extensive than that of an executive director.
Keeping on top of your Statements of Responsibilities is much easier with a great SM&CR compliance solution in place! Why not get in touch to see how Corterum can help?
