• New SMF roles and specific responsibilities need to be mapped to individuals within a Responsibilities Map.
• Detailed documentation on the scope of the individual’s responsibilities is required.
• Senior Managers Objectives and Risk appetite are aligned to that of the Bank overall.
• Banks need to ensure individuals are ‘fit and proper’ both when hiring new senior managers and on an on-going basis.
• Banks need to ensure processes and controls are mapped.
• Produce attestations to show clear accountability amongst senior managers.
• Senior managers are required to take steps to prevent regulatory breaches in their areas of responsibility and to show adherence to Conduct Rules.
Financial Institutions must have a robust IT System in place which:
• Is able to easily map key employees to defined responsibilities.
• Identifies individual roles and responsibilities at any given time.
• Banks need to be able to present historical snapshots to regulators should they require it.
• Have a workflow driven Regulatory Risk Assessment and Controls Effectiveness Assessment.
• Provides version controlling and audits for all key documents.
• Is flexible to cope with complex organisational structures.
Banks need to bear in mind that the decision to certify or not to certify an individual as fit and proper may be challenged by employees and their lawyers, or by the regulators.
The annual certification process will therefore need to be robust and well documented, showing a clear and transparent decision-making process.
The infoFINIUM Compliance Framework has been tailored to address these ongoing dynamic requirements.
infoFINIUM is pre-configured to manage Attestations, CPD, ‘Fit & Properness’ of employees, generate Responsibility Matrix and SMF Matrix, all of which can be implemented to help banks comply with SMR framework.
Deadline for firms to issue certificates for individuals falling within the Certification Regime (Banking Reform Act, Section 29)
Date from which the conduct rules apply to staff who are not within the SMR or CR.
SMR and CR expected to be extended to all FMSA authorised firms.