First, we took the time to truly understand our client’s business, its commercial drivers and challenges. Then, we designed a review process that balanced this with FCA expectations, taking into account industry best practice.
This included a thorough review of its SMCR arrangements and a remote desk-based review of its documentation – all backed up by video interviews with key stakeholders. We considered:
- How appropriately our client had identified the senior management and certified population, and allocated responsibilities.
- Whether the statements of responsibility and certification process were up to scratch.—The effectiveness of our client’s process for assessing fitness and propriety.
- The effectiveness of the governance arrangements, including oversight, monitoring and record keeping relating to the implementation and ongoing maintenance of the SMCR framework.
- The quality of the scheduled training plan, process and record keeping arrangements for the conduct rules.
- The effectiveness of policies and procedures to assess adherence with the relevant rules and guidance.
Having presented our findings in a high-level written report, we worked collaboratively with our client to discuss the findings and outline improvements that could be made. What’s more, as culture experts, we also provided insight on how they could improve their culture to support their SMCR efforts, taking their approach to the next level.