The danger lurking in a Statement of Responsibilities
Updated: Mar 1, 2021
I am working with senior managers to complete their statement of responsibilities forms, much of this is straightforward but we do struggle with the section called “Other responsibilities” as this seems less clear cut.
Completing most of a senior manager’s Statement of Responsibilities (SoR) form is hard work but reasonably logical and straightforward since assigning Senior Manager Functions and Prescribed Responsibilities forms part of your overall senior managers regime jigsaw.
The Other Responsibilities section is harder as there is much more room for manoeuvre. Broadly, it should include any responsibilities that are not specified earlier in the SoR – the FCA suggests that this could include anything that sits outside business as usual, such as the responsibility for a high profile project.
The challenge is really twofold – firstly what is important enough to warrant being specified as a responsibility and secondly, how should you capture that responsibility ie what form of words do you put into the SoR.
Err on the side of caution – we would advise you to include specific responsibilities even if at first sight some do not seem “high profile”. The result of not taking this approach is that you may leave gaps in responsibilities and expose yourself and your firm to risk. Clearly, adding more responsibilities is more work now and more updating over time so there is still a balance that you need to reach.
Focus on “what not how” – SoR’s and relationship maps are all about defining clear areas of responsibility and ensuring that there are no gaps. The only way to do this is to focus on what a manager is responsible and being very clear about boundaries of responsibility.
Keep it straightforward – the way that you describe each responsibility should be clear and easy for anyone to understand, whether they are regulators, other people in your firm or Senior Managers themselves. You should also keep it succinct, the FCA suggests no more than 300 words for each responsibility.
Owned by the senior manager – the SoR is assigning responsibilities for which a senior manager will ultimately be held accountable. You cannot complete a SoR and describe Other Responsibilities without the deep involvement and approval of the senior manager concerned.