"When I first came across SMCR in 2016 I was struck by the ambition of the regulation and how challenging it would be for financial services firms to implement it - SMCR seemed both different and difficult."
Founder of The Rules Consultancy
SMCR is different because its ultimate goal is culture change, it is attempting to drive a culture of increased individual accountability across the financial services industry. This makes SMCR a novel sort of regulation, its outcomes are often intangible and not easily measured in traditional ways.
SMCR is also difficult for firms, firstly because it gives them an awful lot to do, it touches almost every part of a firm's operation, but also because it is hard for a firm to know when they've done enough. What does a culture of individual accountability actually look and feel like? How do you measure accountability in order to demonstrate that your firm is compliant?
The technology challenge
We have known for some time that technology has a large role to play in the successful implementation of SMCR. Fitness and propriety assessments are crying out for automated workflows, regulatory references need to be processed consistently and fairly, conduct rules training needs contextual e-learning with regular reinforcement.
There are many sophisticated solutions already on the market that can provide all of this and more. The challenge for a firm is not availability but rather selecting the right solutions and integrating them in a way that meets the firm's specific context and needs.
The Rules Consultancy
It is this set of circumstances that motivated me to set up TRC. Our purpose is to help financial services clients to select and optimise software solutions that help them to comply fully with the Senior Managers and Certification Regime. We work with clients ranging from small wealth managers to large high street banks.
We are an independent consultancy offering objective and impartial advice. We combine a deep knowledge of the regulation with extensive and up to date research of the SM&CR software vendor marketplace. We also have decades of experience of building and maintaining strong partnerships between clients and software suppliers.
We don't believe in vague, generic consulting so the business is built on two services that have clear steps and deliverables and are offered for a fixed price wherever possible - we know from experience that this is a win for everyone.
We also like to share our knowledge as freely as we can through our blogs and social media, our experience is that this approach opens up dialogue and learning in a way that is good for the industry and good for us.
I would be delighted to talk to you about any aspect of SMCR whether that is about technology or different ways of measuring culture change! Just press the button below to send me a message.