Software to support the Senior Managers Regime (SMR) – A starter for 10

The new Senior Managers & Certification Regime will come into force for Banks on 7 March 2016. This new regulatory regime will then be applied across Financial Services over the next few years.

Many Banks have started their preparations for this major regulatory change (those banks that have not started, should get started!). As part of their overall approach to the SMR, banks are starting to consider software solutions to enable them to effectively meet their current and on-going regulatory obligations under the SMR.

Not surprisingly, there is a lack of clarity about what are the requirements for a software solution to support the SMR so here is my ‘Starter for 10’ requirements.

'The important word is not "presumption" or "duty" but rather "responsibility", it’s about holding people more personally to account' says Andrew Bailey of the PRA

'The important word is not "presumption" or "duty" but rather "responsibility", it’s about holding people more personally to account' says Andrew Bailey of the PRA

In his speech at Mansion House on the 22 October 2015, Andrew Bailey highlighted three topical issues including the Senior Managers Regime and the impact of the change of 'Presumption of Responsibility' to 'Duty of Responsibility'.

FCA CP15/31 and PRA CP36/15 Strengthening Accountability in Banking Highlights

Proposals for regulatory references were outlined in the consultation paper published by the regulators on Tuesday [6 October 2015]. Firms are already required to provide references upon request, the new regulation requires Firms to request references for people that fall within the Senior Managers and Certification regimes.

In the Media: The Senior Managers and Certification Regime

The Senior Managers Regime has received a multitude of press coverage over the past few months due to the announcement of additional rules (and the broadening of the existing rules) by Mark Carney, governor of the Bank of England, in his speech in June. The 'final rules' were released at the beginning of the July in CP15/22 Strengthening accountability in banking. The rules establish Carney's aim is to create a ‘culture of accountability’ by introducing precautionary, precise and punishable measures.

See some of the key news coverage below.