First things first, you need to address any barriers to cross-departmental working. They’re common in businesses that are particularly large or have a complex structure, but collaboration is vital for ongoing SMCR compliance. While a solid SMCR plan may have been developed by your Risk & Compliance team, a new innovation in Product Development or a change in HR strategy could easily make it obsolete.
Leavers and joiners, particularly in senior management positions, will inevitably present changes that need to be addressed. Your Statements of Responsibility and responsibility maps will need updating, with an effective handover process in place and further training rolled out if necessary. And don’t forget about FCA notifications, including updating the new Certification Directory.
Updating HR policies & procedures
With culture and the conduct rules an important part of SMCR compliance, any changes to HR policies and employment contracts must be reviewed, taking into account the impact on standards of conduct, staff motivation and cultural drivers.
Moving into a different market, expanding to a new location or developing a new product line? Significant changes like these could create new Senior Management or Certification functions, or even impact your regulatory permissions, and should be considered with your SMCR obligations in mind.
Changes to FCA rules or guidance will impact many aspects of your SMCR arrangements, so your plans should be adaptable and agile enough to respond to regulatory changes.