Wild Horses in Black & White


A new type of regulation

My background is a mix of financial services, strategic IT and culture change projects  slowly assembled over the last 30 years with clients ranging from big banks through to small wealth managers. 

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. 

SMCR is different because it's 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 Rules Consultancy

It is this context that motivated me to set up TRC. The scale of the challenge presented by SMCR  suggested that firms might occasionally need expert and objective help. This is our purpose, our services are entirely focused on the Senior Managers and Certification Regime, we don't do anything else.  


We work with clients on two levels. Firstly, we help them to be certain that they have done all those tangible things they need to do to be compliant. We are told by the FCA that SMCR is not a box ticking exercise but we know that our clients are anxious about putting in place all the regulatory assets that will prove compliance. We deliver peace of mind by helping our clients to do this well, leaving no gaps or weaknesses. 

The other part of our work is helping our clients to locate where they are on their SMCR journey. We understand culture change and have worked hard to develop tools and techniques that we can use in very practical ways to help our clients to understand and measure their culture of accountability.  


This matters on a hard, commercial level - over-investing in SMCR when your firm already has a strong culture of accountability can be an expensive detour. Under-investing in SMCR can leave gaps and weaknesses that expose your firm to considerable regulatory risk. 

Our style

The Rules Consultancy is a growing group of highly experienced and skilled consultants whose knowledge ranges from the employment law considerations of a regulatory reference through to creating a psychologically safe culture that does not inhibit whistleblowing. 

We don't believe in vague, generic consulting so the business is built on a set of structured 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 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 your practical challenges or different theories of culture change! Just press the button below to send me a message.

Best wishes,


Jon Ellis, founder of The Rules Consultancy
Jon Ellis, founder of The Rules Consultancy, specialists in SMCR and culture change