Senior Management Regime (SMCR) Starts to Bite

Abstract

As a Senior Manager (as defined by the Act) you are personally responsible for the actions and conduct of those employees who report to you and have been since SMCR bit; in the banking sector in March 2016 and Insurance sector in December 2018. Until now SMCR has been regarded as a relative non-issue with low level fines and no custodial sentences, yet.

But, all of a sudden, the markets are alive with chatter that FCA is finally focusing attention in this area. SMCR makes it clear that senior managers are accountable for the actions of the staff and functions they manage.

The tricky bit would appear to be just how does a senior manager audit the relevant knowledge and capability of the (often huge) team they lead? Post training assessments are all but useless in determining relevant levels of actual employee knowledge and competence and as few firms have any credible alternative, most senior managers are currently flying blind.

This short paper looks at the sheer scale of the problem facing most Senior Managers and explores how more firms are turning to a continuous assessment methodology powered by Artificial Intelligence to protect their Senior Management and their brand reputation.