The challenge

A leading insurance broker had been busy preparing for the new Senior Managers and Certification Regime (SMCR). Its in-house team had spent a lot of time doing a comprehensive gap analysis and making the necessary changes to the firm’s policies and procedures. With all the time and resources they had already invested, they needed to make sure they'd covered all bases before submitting their evidence to the FCA. ​

Our solution

Having worked with us before, they knew we had the right experience of managing regulatory change programmes. Our review included:​

An in-depth analysis of our client’s implementation programme, looking for potential gaps in the allocation of responsibilities, missing documentation and deficiencies in new and existing policies and procedures.​
Interviews with key managers.​

Benchmarking our client’s approach against other similar firms we had worked with and advising our client what they needed to do to meet industry standards.​
Benchmarking against common misunderstandings and issues identified from intel from the banking sector implementation approach. ​

We identified some gaps and overlaps in allocation of responsibilities and recommended where reasonable steps could be better evidenced. We also suggested updates to  existing policies that had originally been missed, including the recruitment and selection and performance management policies. Because we spotted these issues early, our client could take action immediately, before submission. ​

SMCR is not just a box ticking exercise but a holistic rethink of internal culture. So, as well as giving our client peace of mind about their SMCR compliance, we also outlined the wider implications of the accountability regime and made recommendations on how they could foster a healthy culture that promoted a successful and sustainable future. ​

The TCC difference

Our wide industry knowledge and regulatory expertise meant we spotted weaknesses in our client’s approach, which were missed by its in-house team. ​

By engaging us to review their SMCR implementation early, our client could quickly make changes before the approach was embedded, saving them from costly reworks. ​

Because we understand the link between culture and SMCR, we identified areas of the client’s internal culture that could be enhanced, ultimately bringing about better long-term customer and commercial outcomes. ​