The Senior Managers and Certification Regime (SM&CR) has replaced the previous Approved Persons regime, with the onus of certification (including designing and maintaining a suitable certification process) now being placed on firms themselves.
Firms can either manage this process internally through their HR and Compliance departments and / or seek some form of assistance. Areas of focus include process design, management, assessment, training and independence.
OCREUS can provide for this, assisting firms’ management teams to design or enhance the SM&CR process, or to conduct the SM&CR annual reviews and certification.
Key activities might include:
- Documenting prior Certification process (if required / appropriate)
- Highlight gaps in process versus current regulatory requirements and suggest process enhancements where required
- Review and/or help compile Management Responsibilities Map and Prescribed Responsibilities, and ensuring alignment
- Provide advice on creating role profiles from job descriptions and aligning these with the MRM and Statements of Responsibility
- Design questionnaires, briefing sheets and other artefacts to be used as part of the annual FIT-compliance certification process, including interviews and self-assessment declarations
- Tailor and deliver FIT-focussed competency-based certification interviews
- Provide feedback, certification recommendations and development points to the board.